Date: 24 October 2003
Event: 450-470 MHz Band Realignment Open Forum,
hosted by the Spectrum Management Advisory
Venue: The Royal Society, London
Chairman: Michael Short
Smith Bernal WordWave Limited, 190 Fleet Street, London EC4A 2AG
Tel: 020 7404 1400 Fax 020 7404 1424
MICHAEL SHORT: My name’s Mike Short and I’m very pleased to have the chance to chair
this open forum today. Wee are recording today’s proceedings, so what I want to do is to
both make sure it’s interactive but be aware that as we are recording these proceedings, that
you will be recorded. So, if you have any problems with that, then I’d rather you say, but
when we do make it interactive and I ask for questions from the floor, please indicate your
name and your affiliation so at least we’ve got a record, particularly for those people who
couldn’t be here today. It’s not that we’re trying to trap anybody into making inappropriate
comments; it’s that we want to make sure other people who couldn’t be here today can hear
the proceedings after the day’s event.
So, I’m here as a member of SMAG, the Spectrum Management Advisory Group and I have
been a member of it for the last five years. I’m not here as the vice-president of o2 or as
Chairman of the Mobile Data Association. I agreed, as a SMAG member, that it was a very
important subject and that we had an open discussion on this area, I hope it will be a very
open discussion today because I know from the SMAG discussions we’ve had, and from the
industrial input we’ve had, that there are a lot of concerns but also quite a few opportunities
in this whole area. So, in order to make sure that we cover the ground, this is the agenda
I will briefly cover the introduction objectives now and, after Hazel Canter, Paul Jarvis - Head
of Private Business Systems Unit (RA going into Ofcom) - is also going to talk about some of
the background and the milestones in this particular band for transition from “old world” to
“new world” and how we can handle that on a timely basis.
Some of the industrial concerns: - we’ve deliberately taken three valued speakers who are
very knowledgeable in this area. Alan Hudson, as a director of the FCS, is going to speak
first and Adrian Grilli from the Joint Radio Company, more from the utilities angle and then
Derek Banner, OSCA, on site paging. So, you’ve got three viewpoints, in effect, on the
industrial concerns. This will be followed by something on the economics and statistics of
transition. I’ll then have a panel discussion with the speakers, so that we can have
everybody up here, so you can ask questions to them jointly rather than individually and then
I’ll conclude with some remarks and perhaps a way forward and close by 12.45pm. So, I
hope that’s okay with all of you on the agenda.
Most of the papers that have been presented today - not quite all, but most - are in the packs
that you’ve got in the binder that’s been made available by RA. Thank you very much for the
support from Radiocom’s agency, Karen Scott and Natalie John, for helping to set up today,
so SMAG can’t claim all the credit for organising this!! We just said, “We thought it was a
very good idea to have this open discussion”. And what we wanted with the objectives to be
were, looking at this very simply, to take into account with the longer-term realignment
project and just make sure that it was going down a steady or a reasonable course. SMAG,
as a spectrum advisory group, has been around for five years but we have specifically
responded to the RA consultation document in this area and, in fact, in the annual report for
SMAG, page 24, there is a brief reference to it and, indeed, to today’s open forum.
The reason we want the open forum is for these three specific objectives though: to make
sure this wider discussion can take into account industry concerns; to examine in more detail
the costs associated with transition from “old world” to “new world” because I don’t think,
necessarily, the costs have been fully understood ( and also how the costs can be recovered
in some way, but in particular then, to explore a way forward for the realignment, the “old
world” to “new world”. So, I hope that’s a fair set of objectives.
Just in case you’re less familiar with the work of SMAG; we were established partly by Act of
Parliament in 1998 and it’s an independent group of specialists. In the annual report that’s in
your pack today, you’ll have the full membership list. There are 11 of us; some of us have
been there since the beginning. John Forrest, the chairman of SMAG, retired in the summer
and Ed Richards who is now in Ofcom as senior partner, Strategy and Market
Developments, is the acting chairman appointed by Stephen Timms. We have a meeting with
Ed Richards in November and also one planned for December and at those particular
meetings, we will look at the way forward and at some of the key issues that SMAG should
look at. But some of the examples that have been on our work programme include the
management of licence exempt spectrum; spectrum trading; broadband emergency
communications, not just narrowband; some of the areas to do with longer-term software
defined radios, how can they play a part, what role will they play in the future; ultra-wide band
technologies and “spectrum commons”. Now, they might seem high-brow and long-term but
actually there needs to be discussion, both with RA and with Ofcom in the future, about how
these will play a part in the variety of industries which use spectrum. Any inputs to SMAG,
from any of you, are welcome at any time. RA today, Karen Scott provides the secretarial
administrative support to SMAG and some of the activities we have got going forward will be
plotted and planned for with external visitors, as usual, very soon for the year 2004.
So, with that brief introduction, that’s really the objectives of the forum. There will be
microphones for any questions that you have throughout the morning. What I’d like to do
though is to swiftly hand over to Hazel Canter who, I think, your official title now, Hazel, is
Director of Spectrum Services, Executive RA, but as many of you know is also going into
Ofcom in her new capacity and maybe you’ll say a few words about that, as well. Thanks,
HAZEL CANTER: Good morning, everybody. Thanks very much to SMAG for hosting this
forum and I think it is a good idea to have a specific space in this area.
As Mike says, first of all perhaps just a little bit of update on Ofcom before we move to band
realignment. We’re at the stage now where the vast majority of people know if they’re
moving to Ofcom and I think the Radiocommunications Agency physically moves in mid-
November, about three weeks’ time. The thing to say in relation to this particular area is that
you will find that there is considerable continuity of staff in the move across to Ofcom. It will
still remain, at least partially but possibly totally, my responsibility to deal with band
alignment. It will still be with Paul and Malika, the same team, who are dealing with it, so you
will be dealing with the same people. There will not be a major change in the actual staff.
Now that might be a good thing as far as you’re concerned, it’s a good thing as far as I’m
concerned. The same team are moving across and we will be taking the project and the
issue and the work with us.
I think one thing to say though is that there may be, as a result of Ofcom’s rather greater
orientation towards market management in the spectrum, we may well find that more
resources are available to us to actually help deliver the project and that will be a good thing I
think because we are beavering away with quite a small team and doing it over quite a long
period. I certainly would like to be arguing for a few more bodies to help deal, particularly,
with some of these technical issues that are emerging as we go through. So, I shall certainly
be arguing that case in the debates about resources in Ofcom.
Just a couple of things to say about Ofcom - it is clear and I think it’s signalled from the way
Ofcom’s structuring itself, first of all, it does want to be a regulator that looks at issues from a
converged point of view. That was the raison d’être for its existence and there is every sign,
with the structure of the organisation that they are going to want to look at issues in the round
and I think that on the whole is a good thing for the communications industry generally.
Those of you who have previously had to deal with a number of individual regulators about
specific aspects of your industry will find that that is not the case and so hopefully, over time,
things will be a bit more focused. I think the other thing to say is just to reinforce that they
really are committed to market management of the spectrum and I know there are some
concerns about this but I think they feel that the management is actually you guys and they
don’t feel that it’s appropriate for the regulator to second guess decisions which should be
made on a commercial basis and they want to facilitate arrangements that enable market
methods of management to help those users of the spectrum in the industries to flourish and
so on. And that will be a stronger perspective than in RA. There are certainly more
resources and there’s more orientation to that, the fact that the chairman of Ofcom is an
economist; the fact that the head of strategy and research is an economist and so on and so
forth. It will be that sort of approach.
I know that itself brings some concerns about where are the technical guys and the one thing
I would say to you all is that the vast majority of the engineers who worked for the RA are
moving across. There is a wide recognition within Ofcom that the engineering expertise is
absolutely crucial to the evaluation of spectrum use and also economic management of the
spectrum. So, it’s not something that’s being ignored.
So, having said all of those things let me just move on and talk a little about band alignment.
The first thing to say is I want to be perfectly straightforward with you. I know that this is of
great concern to many of you sitting in the room and one of the things as a regulator you find
is that you are often in a position where you are having to negotiate access to spectrum for
new users with existing users. That, in a sense, is at the core of the job and a number of you
in the audience have been engaged with me in it. It isn’t “we’ll work together” / “we won’t
work together” debates, both in terms of industries who are affected or companies who are
providing information about it. And that’s, in a sense, the core of one of the tasks that we
have to do when we regulate the spectrum and in this particular area, I also know that there
are a number of specific concerns.
First of all, there is a lack of clarity so far about, if you’re going to have to move, where you’re
going to move to and on what sort of timeframe. Second of all, there’s no clear sign of any
funding to assist you. Third of all, there are some concerns about whether or not these
changes may be necessary and fourth of all, I think there is a feeling that we may be
underestimating or not listening to you in terms of the technical problems. Without making
too much of it, in a sense, Paul will give you a detailed description of the work that we’ve
been doing on all of those fronts to try and address that issue. And we are very concerned to
making sure that we do listen to you, particularly about the technical aspects and see what
we can do to deal with it and as Mike said, that’s another of the advantages of actually taping
the event today. It means that we can carefully pick up all the queries and issues that you’ve
listed with us and try and deal with them but it is a situation where again, for very many of
you working in this band, you can see only disadvantages for a possible move and our
difficulty, of course, is that the move will create opportunities both for your industry’s
expansion and for other industries to use the spectrum. One of the crucial things to bear in
mind is that, Paul tells me that on average, every month, we get about 160 queries for
access to either UHF1 or 2 and that’s a lot of queries, many of which we can’t deal with at
the moment. So, it’s not as though the band you’re in is not tremendously sought after, in a
sense, so there’s a demand out there but we really have to think about how we’re going to
The other thing is, as the economic studies will show, this is very valuable stuff and it’s
valuable stuff not on the basis of revenues back to the Treasury, I think the economic study,
at least, gives the bottom end of over £200 million for the value of the spectrum that might be
freed up by this move. Now, that’s not money that goes back to the Treasury, that’s money
that goes into circulation in UK plc, that’s other industries making profits and employing
people and so on, so we would be irresponsible, wouldn’t we, if we just left it. We really
need, on behalf of UK plc, to take action on this and to see how constructively we can
actually move to a situation where we can accommodate more of you.
The other thing too - and again, it’s one of the nice things about doing the opening remarks is
you can steal the thunder of some of the other speakers; sorry about that - but the other thing
to say is that there have been some changes to other spectrum that is also available for PMR
users in relation to an announcement, which I don’t know whether many of you caught by
Geoff Hoon, about an upgrade at Fylingdales. The upgrade at Fylingdales will impact on the
availability of similar spectrum in this area and so it becomes even more important that we do
have a serious look at this band.
I don’t really want to say very much more. Its seems to me that what we need to do is get
into the detail of the work that has been going on so far and hear your thoughts about it and
we are very committed to making sure that you try to address all of them but just one last
thing to say. The Minister has signed up to this move and on some timeframe or we are not
for turning really, is what I want to say, this will happen. It may happen faster or it may
happen slower - that may depend on compensation - but this is going to happen and it really
has to because otherwise you will find that your industry can’t expand either and so we’ll all
be in some difficulty.
The final thing for me to say is I am sorry. I would’ve liked to stay all day but I’ve got to go
elsewhere. But anyway, I hope you all enjoy the day and please do be forthright and frank
with us about what the issues are because we do want to hear you. Thank you.
MICHAEL SHORT: Thank you. Paul is going to give a background and propose
implementations that are milestones to this particular transition, so listen carefully and we’ll
take some questions at the end of Paul’s presentation before we hand over to the next
PAUL JARVIS: Good morning. What I wanted to talk about was just a little bit of
background and a lot of you will be very familiar on what’s gone before and how we’ve got to
where we are but just so that we go through a bit of revision, we’ll wind the clock back and
run through some of the events over the last couple of decades which has forced us into
reconsidering this band.
The most important thing is the implementation phase which Mike referred to and the part
that industry will be able to play in the form that implementation takes. And a little bit of
background there on the tools that we’re developing within the agency, within Ofcom. We’re
just literally calling it the ‘band alignment tool’ at the moment and it may well get a sexier
acronym in due course. And then towards the end of the presentation, the next steps, what
will be happening in the next couple of years and in true form, just summarise all that right at
the very end.
The history of band alignment really goes back, as far as I can make out, to about the 1970s
when various people were beginning to get concerned that what the UK was doing was
slightly different to the rest of the continent and as other large networks rolled out, they were
proved to be right in as much that we were exposed to varying degrees of interference. So,
that really triggered quite a lot of work and I’ll go on to detail that in a little while but there
were various contracts let to studies and, in fact, the DTI at that time put quite a lot of
resources into doing some of the early costings for aligning the band and what needed to
happen and, of course, right back then, it was identified that to do anything with this you
need some space in the spectrum to start moving people around.
So, the drivers even then were interference; it’s become more important that we consider
harmonisation, what opportunities that might bring to the UK and, as we know over the last
three or four years, new technology. It’s very difficult for us to get a foothold in this part of
the brand mobile spectrum for new technology, so that is another important driver. Hazel
indicated that we’ve got to co-ordinate with RAF Fylingdales in a much bigger way than we
have in the past and that’s definitely going to lead spectrum scarcity within UHF, so another
very good reason for us examining what can be done here. And then, if we do get this
opportunity to replan UHF, how much spectrum can we yield from the replanning exercise as
well as that coming back from the Home Office? And behind all that, we want to keep this
eye that Hazel indicated (even more important within Ofcom), on the competitive
environment. With all those things in the back of our mind, the Minister has given his
commitment to us that we should press ahead with aligning the band.
So, harmonisation: we believe that will minimise continental interference and it’s fairly
obvious that, again, there are some figures done that were in a earlier report, that if we
actually don’t have base station receivers looking at base station transmitters on the other
side of the channel, then we’re going to be better off and that has been quantified. I do have
the figure a little later on; it’s around about 32dBs better off in terms of isolation of continental
interference. It will give us a chance to introduce new digital technologies. There’s nothing
to say we can’t introduce these digital technologies on the current format but the problem is
the manufacturers want to standardise and they want to make equipment that’s got standard
filters, standard spacing, for example, and it seems very appropriate that if we’re going to do
this, we take this opportunity to maximise all the benefits. It will mean that for certain users,
being able to roam across Europe on the same frequency, using the same technologies we’ll
be opening up and possibilities of new business avenues there. And then I believe that in
actually going through this process will put the UK back at the forefront of PMR. PMR: we
know we’ve got of lots of addict calls every week for people that want to integrate PMR into
existing intranet type applications but can only really do that effectively if they’ve got the
You may have noticed, on the introductory slide, interference was at the top. I’ve actually put
that towards the end of this introductory section because I think it’s quite important. I think
it’s actually slipped to the back of our minds in the last few years.
The new technology that we’re talking about is tetra. As you know, there are really only two
bands in the UK that are open to tetra. One is the emergency services band in 380, 385,
390, 395 and the other one is the Inquam dolphin spectrum at the bottom end of UHF1 and
what we would like to be able to do is introduce, not only tetra, but any of the other digital
technologies. Tetrapol’s there; I think we can consider it to be digital but it is a sort of
analogue interpretation and digital mobile radio which was known as DIIS until last year but it
sort of reincarnated in a more generic term and being developed within ETSI at the moment.
And that will give us a foothold for narrow band systems in the market and also, once we’ve
gone through the harmonisation process, if we carefully replan it, it could open the door for
wider band systems such as CDMA applications if that’s what the UK and the UK industry
want to do. So, it basically opens up those new possibilities. It gives us the same sorts of
features that you may already be expecting to see in some of the public operations, certainly
the Inquam type application. We will be able to integrate the digital parts of PMR with
intranet services, so it will be still closed user group but possibly have on-site services in one
location but if you’ve got stores in another county, then use your intranet that already exists.
And, of course, it gives us the possibility to integrate voice and data to a much higher level.
Spectrum scarcity: I’ll give you a little bit more background on the Fylingdales situation.
UHF1 has got 24 25,000 licensees in it at the moment and a handful of those licensees
cause the early morning radar to be handicapped to a certain extent and, of course, with the
international issues around terrorism, etc, at the moment, it’s very important that the early
morning radar is able to do its job - not only for the Americans, who actually pay for the
system - but the UK get some benefit as well in terms of intelligence back to our military. We
need to bear that in mind and we’ve been asked effectively by the Secretary of State for
Defence to protect the radar from further degradation. Now, we’ve had to fight very hard to
freeze the position as it is, rather than clear the band, we’re on a knife-edge in terms of which
way this could have gone but we have, in fact, secured access to UHF1 with the condition
that we won’t allow the interference environment to worsen as far as Fylingdales is
What that means though is that we’ve basically frozen what we’ve got in the band now. It
gives us very little opportunity to do anything new and we’re at this very moment working with
both the MoD and the Americans to take a snapshot over a couple of weeks of what the RF
environment is and that will be interpreted to give the baseline - we still have to work out how
we’re going to interpret that - to give us the planning level for future management of UHF1 .
Now, clearly that gives us quite serious constraints about what can go on in that band and it
means that UHF2, if you want a UHF solution, is the only opportunity but everybody knows
that over the last few years in particular - since about 2000 - there has been this rather dark
cloud called band alignment hanging over UHF2, so it basically means that if we want to go
ahead with this, we’ve got to have a very clearly stated plan. We’ve got to work very closely
with the industry to work out what is absolutely the best thing for the UK for us to maximise
the benefits and I think that is the real crux of today’s meeting and that’s always been at the
back of our mind but it’s even more important with what is likely to emerge.
Band alignment: we’ll also have the benefit now of the MASTS tool, which is the assignment
algorithm that Dr David Bacon has developed within the agency. It’s been validated
independently by ATDI and it’s been given a very good report. It works extremely well and
we’re going to integrate the band alignment tool which will maximise the use of spectrum. I’ll
show you very roughly how it will work in a few minutes. The tool will pick out individual
channels, all the people that are associated with that channel in a geographic area, pass the
information over to the MASTS algorithm and it will do the coverage plan and all the other
criteria, the intermodulation calculations, etc, and give us a rating of how successful that
move of frequency is likely to be. So, that will come with a little bit more detail in a moment
Competitive environment: we know that GSM and GPRS is actually taking quite a lot of
business from some of the PMR users and a lot of that is because it’s got the digital facilities,
the data facilities. PMR has been historically the choice for many businesses because it can
be tailored to their precise requirements, whether that’s for voice or whether it is for data.
There are data services operating at the moment but what we want to do is to be able to
make this much easier to integrate the new technologies, give them a proper footing to
compete with and even work with the GSM, GPRS facilities. Also, another very important
issue is the security of tenure. If you go through this process, how long are you going to be
able to keep the spectrum? So, we want to address that in this whole process. Now, we’ve
got to work out what the figure is. Maybe it’s 10 years, maybe it’s 15 years before we review
it or maybe we’ll always leave it open-ended, but they are issues that we need to work with
you to sort out.
And also under Ofcom, we’re moving towards trading and tradable licences. It’s very
important here that we look at the configuration, look at what sort of trading could be
permitted and if we wanted to, it would mean that we’d have to have in there, the caveat, that
if you trade the licence, it might have to be realigned. Now, at the moment, our thinking is
that it would be better not to trade there until we’ve gone through this process and then let
the market decide how the spectrum should be used from that point onwards but again, we
need to work with you and sort the detail out. Certainly our current thinking is the fact we’d
be better off going through alignment while it’s under our control, rather than lots of people
changing spectrum use over.
Spectrum yield: with the band alignment tool that I mentioned and the MASTS algorithm,
we’ve done some preliminary work and we think that if we were to replan all the existing
users in UHF2 or all those between 450 and 470, we could actually have a yield of two times,
two by two or two by three MHz, somewhere between, just by better planning rather than the
rule of thumb process that is effectively been used drawing on local knowledge to date. We
know that a lot of users actually want the on-site type applications and we’ve perhaps given
them very generous protection areas where if we can actually, with a lot more confidence,
use the prediction tools to tighten up that, we’ll be able to slot more people in, obviously
makes good sense. So, we think that there’s a 2 to 3MHz paired spectrum yield from doing
the exercise and we might want to do that anyway but it seems if you’re going to cause the
disruption to people, it seems very sensible to go through the alignment process, so that it
opens up the other possibilities, new technologies as well.
Later on, there’s another presentation which I have to deliver on the economics and the
work that the economists have done indicate that if it’s 2 MHz of spectrum yield, it will be
worth around about £247 million. That’s after the costs of going through alignment and if it’s
3 MHz, then it’s £430 million, so these figures are very significant, as Hazel said earlier and
we believe, and in fact the figures so far show that the benefits are much greater than the
costs but, of course, it does have a timeline. You don’t get the return until you’ve made this
quite considerable investment.
Back to the continental interference bit. First of all, we need to consider the countries that
have adopted the TR25-08 report, which is the one that details the spectrum plan for Europe.
It is available in electronic form. There was a working party for continental interference set-up
in about 1998 or maybe even before where various studies were triggered. ST Scicon did a
detailed study - if people can remember - and that came up with a probability factor of getting
interference in various parts of the country and I have lifted a map from that which I’ll show
you in a minute. And it also was really where the decision to start with came from, that we
really ought to seriously consider aligning the band but, of course, then that was before
digital technologies, before lots of other things and lots more water under the bridge and
we’ve now got a new set of circumstances, the least of which at the moment is interference
from the continent but that’s because the continent aren’t using the spectrum at this moment
in time to any great extent. So, we have got a very top level overview of what the
neighbouring countries are doing and what their plans are and also the charts that were
developed by ST Scicon for the probability of interference.
The green countries are the ones that are already, to some extent, aligned TR25-08. I say to
some extent because they haven’t necessarily aligned all bands. They’ve taken the ones
that they see have priority but unfortunately, you can see it leaves poor old Blighty here well
and truly in the white and we’ve got to very seriously consider what the implications are,
particularly as we hope that continental travel etc and playing more and more of a part within
Europe, comes into focus.
QUESTION FROM FLOOR: Before you take it off, is Luxembourg there in white?
PAUL JARVIS: That is Luxembourg right in the middle. Actually, this is what the other
countries are doing there and I don’t know if anybody can read that actually, you can
probably see it on your notes there but they actually do show that everything is free, at the
moment, so they’re not using 450/470 at all. They foresee it as being for narrow band PMR
use but I think that again is because if they got a good agreement, they’d have huge
problems with co-ordination, being such a small country.
QUESTION FROM FLOOR: Just on that fact, will we see France and Netherlands pursue
UHF1 in Europe, they haven’t responded, in fact?
PAUL JARVIS: Absolutely, yes. Again, the same thing applies to the Netherlands, although
we do work as regulators very closely with the Netherlands. We have a very similar
approach in most ways, in most things and I think it all hinges around the debate over wide
band CDMA and this is why they haven’t made a decision and are not willing to make a
commitment at this stage. But that slide there is extracted from a document that still isn’t
actually public but in due course, it won’t be too long before you see other European
countries and all the details. I picked the ones out that I thought would be of particular
interest to us today. It looks as though on the whole, people are looking for maintaining the
use for PMR in their right of different guises.
QUESTION FROM FLOOR: I don’t want to interrupt your flow but was there a response or a
question out of Ireland?
PAUL JARVIS: Yes, and actually that’s another one that we, for other reasons, didn’t have
a response other than for the fact that, unofficially with this band, they have indicated that
they’re watching to see what the UK does with an indication that they would follow but they
haven’t actually gone and made any statement that they will follow. So, that is an area, one
of things that we’re having to juggle as well. What happens if they don’t and what are the
core issues that that brings to us?
QUESTION FROM FLOOR: Gerald David (Aerial Facilities): Why have you left Denmark
off the list?
PAUL JARVIS: Probably an error actually, Gerald, or I didn’t have any information.
QUESTION FROM FLOOR: Gerald David (Aerial Facilities): They haven’t signed up?
PAUL JARVIS: I think it’s probably one that didn’t respond but I’ll have a look afterwards
and see whether I’ve got anything on Denmark. I think it’s quite interesting. You see that a
lot of the countries there are still very pro narrow band PMR but they want to keep the door
open for future technologies.
The working party for continental interference started its work in 1985, did the studies
between 1985 and 1989 and then, from their findings, the ST Scicon were commissioned to
do some of the calculations for the working party. They effectively asked the RA to provide
them with all the parameters of existing PMR systems at that time, so that was the power
levels, antennae heights, locations, etc. They decided that they would take the median of
that and the median of the systems that were on the continent and calculated that there is a
benefit of 32dBs if we go through the band alignment process and that’s purely from the fact
that we’re looking at relatively high antennae heights for the continental base stations and
then relatively low antennae heights for mobiles because we’re not looking at base station to
base station any more. And that gives you that 32dB mitigation and, clearly, that’s well worth
having. The consequences of CDMA might though be even worse than we knew in those
days when we were exposed to interference.
Unfortunately, I wasn’t at the recent MRUA conference but I’m told by one of my colleagues
that Brian Seedle gave a presentation that indicated that for successful CDMA coverage in
certain circumstances, you can see 30dB higher field strength, so if we don’t align and the
continent does adopt CDMA, we could be 30dBs worse off than we were when they had
NMT 450 transmissions, so something else that we need to be very alert to. I don’t know if
anyone was at the conference. Perhaps they could actually say more on that but I’ll try to
find out more. I’ll try to contact Brian and see whether he’ll give me a one-to-one resume but
he’s abroad at the moment.
The planning stage: planning seems to have gone on and on forever. In 1992, Steve Limb
was recruited and he developed the top level of the new band plan for aligned 450/470. It’s
obviously gone through a number of alterations and you can continue changing these and
refining this forever but it, in fact, got basic industry working group buying a couple of years
ago and we’ve done very little work to it then because other things have been changing that
we needed to keep track of. But nevertheless, the plan is there. We have what we believe
would be a very sensible format for the new layout after band alignment. The working party
for continental interference continued right up 1996 but then, at that point, they knew on the
horizon were the recommendations from the DSR, that the LMT450 Radiocom 2000 systems
would be shot down and migrated to GSM, so I think they thought that most of the problems
would disappear but, of course, it leaves a void.
When we get the opportunity to actually go through the alignment, we need the spectrum
back and the implementation has always been dependent on the roll-out of what was known
as PSRCP and the migration of the police forces onto airwave in the 380/400 band and,
because of that, their negotiations were initiated with NATO to get access to part of that
band. I’m sure you all know, it’s not the whole 20 MHz there; it is only 2 by 5 that we have
access to, 380 to 385, 390 to 395. Time and time again, we’ve gone back to NATO and
asked for the possibility of access to further spectrum and, unfortunately, the door has been
firmly closed because NATO have invested in their own system that goes in the other 2 by 5
MHz - but because of the implications of Fylingdales on us, we’re currently trying to
negotiate access to additional spectrum. So we haven’t given up there. That is still
something that we’re hammering away but, for the moment, there are still no short-term
access to spectrum in that band but if we do get access, it will be more like long-term, not
In 1999, the project definition for the PSRCS procurement began and most of us know the
basic history. Airwave won the contract term. We’re currently rolling out. We have a couple
of people in the audience from Airwave, so if you want to talk to those at lunchtime or at
break, that’s fine.
The industry working group refined the bands. We’ve got a new band plan which, again, is
available in an electronic form. These are in a PDF format if anyone would like to see that
and we’ve started the preparations for aligning the band in terms of looking at what public
opportunities there are: what sort of communication channels we need for the industry; what
engineering concerns there are.
Now, this diagram again is from the DTI UHF interference report which was informed by the
ST Scicon and this line here is a 50% probability of interference, which is fairly obvious that
you were bound to get interference right on the coast, that doesn’t need too much
imagination; 20 to 50% probability, that actually reaches the outskirts of London; 10 to 20%,
most of the southeast right the way across down there to Somerset way, something like that
and then, obviously the 1% figure which is still probably bad enough because most of the
anomalous propagation comes in sizeable chunks in the UK; would probably mean that you’d
be suffering interference or were suffering interference, right across there from North
Yorkshire across to Liverpool. So, I think we need to keep that in mind because if the
continental systems do get rolled out in a new form, we can expect to see this sort of
interference problem on our current configuration. Now clearly, it won’t be empty for 50 or
Radiocom 2000, so it might have different characteristics but the potential is still there and,
as we could see from the table earlier on, the different countries are considering what to do
with the spectrum here and now and may well, in a few years, start to take us back to where
we were in the late 1990s.
You might want to close your ears at this point. I’ve actually got a little sound clip. I hope
everybody can hear that (clip of interference played to audience). This is normal PMR of our
independent systems that monitored but back in the archives. It’s a control panel with PMR
in the background. That was UK PMR with a backdrop of continental interference, as some
of you will recognise. I’m sorry it’s very quiet but this really did come from an old tape
archived from Baldock. Some of you, I’m sure, will recognise the racket and if you were an
operator you’d be most annoyed if you had 24 hours’ worth of that.
Paving the way forwards, we’ve been formally working with industries since 2000. In fact,
the last 12 months, we’ve not done so much in the industry working group because we’ve
had to go through the process of informing the Minister. We put a lot of effort into developing
the ideas for the software band alignment tool and, of course, the planning for our arrival in
Ofcom has taken over quite a lot of effort but in 2000, we gave the official notice of intent to
all the UHF2 licensees that we were going to align the band. In 2002, the Minister gave his
broad approval to aligning the band. He did state to us that we must make every effort to
minimise the impact to industry but he could see that this was perhaps, in a way, the way
forwards if we could get the planning and get the industry to help us get this very ambitious
project underway. 2003 saw the consultation which brought quite a lot of the industry
concerns to the fore and what we’re currently doing and have been doing for some time - is
exploring the various possibilities for funding. I’ve met with representatives from the
Treasury. We have to make sure that if we go for funding it’s not seen as state aid, it’s not
going to distort the market and the five tests that go with that. So, it’s a bit of a minefield but,
nevertheless, we’ve got a dialogue with Treasury. We know what we’ve got to do to identify
Some questions are still outstanding: whether we treat this as one huge project or whether
we can treat individual licensees effectively on their own merits and there’s pros and cons to
both approaches. In a sense, it’s a lot easier to get a big pot of money for the overarching
case but then we’ve got to administer that, we’ve got a clause to dishing the money out. The
other side of the coin is if we actually go for the individual licensees and the vast majority of
cases, any kind of compensation would be in the de-minimist category, so there are less
constraints and less hurdles to cross but still, we have the administering process of that and
these are all issues. Don’t have the answers at the moment but these are issues that we’re
currently pursuing. I guess it would be fair to say that we’re not going to be pursuing them
during November but perhaps as soon as we get into our new guise after vesting day, there’ll
be a lot of effort put into identifying the way forwards there. But it boils down to meeting the
five tests that make sure that we’re not distorting the market and the fact that it’s not deemed
to breach the state aid rules.
Implementation really is the very next big thing. We need to resurrect the industry working
group in a new guise that is purely looking at the implementation of the band alignment and
we feel now that having had the lead in this, in terms of the regulatory position, it’s now time
to let the industry get a much bigger part in this and we hope to appoint an independent
chairman for the industry working group. We’re actually currently thinking that that will make
sense to do this in the spring and you’ll see why in a moment. It’s because the first release
of the IT tool for band alignment will be in the spring and I think it’s going to need engineers;
it’s going to have informed industry representatives working with this tool to then maximise
the benefits of going through the alignment process. So, when we know the tool is available,
we’ll resurrect the industry working group; we’ll jointly or somehow between us work out who
to chair this independently. It won’t be someone from Ofcom; it will be someone from the
industry and then we start to move that forwards. Later on then, the IT tool will have the bits
that link it into MASTS, so that won’t be available at the first release but you’ll see a little bit
more about what it will be able to do in a moment.
We then need to develop the implementation project plan, which is all the detail of what it
means to each individual stakeholder. We need to get them informed. The communication
process will evolve, obviously. The dealers; there’ll be lots of different companies that need
to be carefully engaged and I’m looking here to make sure that the trade bodies - for
example, the FCS - will be able help us work together to communicate the plans and to
address the concerns that come out. There are users and I know some very important users
that are here that we haven’t resolved problems with. We’ve been working with them and we
still have problems, we haven’t resolved them yet, so we’ve got a lot of work to do together to
sort this out. We also need to keep our regional staff fully briefed because we all know that
while we’re on shared sites, if we turn someone round, we’re going to have at the very least
the noise floor problem so we need to have people in a position to help resolve any specific
issues. And I think there aren’t enough of us in Ofcom to do it and there probably aren’t any
individual companies, so we need to identify contractors wherever we can that will be able to
take the work forwards.
This is a screenshot of the development so far of the band alignment tool. What we’ve
actually got - this little square here - is the area that we’ve decided that we’re interested in
and all the different colours that we see across here are the different types of use in the band
at the moment, colour coded, and we’ve got the frequency range on the scale at the bottom.
We can pick a chunk of the spectrum with a little window that you can stretch out to whatever
size you like and then the details of that are shown at the top. So, we can actually go there
for one to two if we go down to individual channels but then the next bit behind that is that
every single licensee’s details are pulled up for the bit that we’ve selected. Now, that’s the
important bit from our point of view because on a geographic basis, that can be sent across
to the MASTS algorithm to do all the calculations on the site compatibility and the coverage
and, in fact, the MASTS will introduce the greater quality of service measure as well and that
really is the most important bit. In a sense, we started off here thinking, “What we really want
in UHF2 is a very fancy disc defragmentation algorithm but it needs quite a few more
dimensions to it”. So, when we thought about that, if someone can sit down and work out
this algorithm, we could go home at 5.00pm on a Friday and come in on Monday and it
would’ve done all the planning for us and it’ll work. Very nice, if you could actually work out
how to write the algorithm, so it obviously is an iterative process but we are well on the way
to being able to handle the physical figures and the details from sites on a geographic basis
and be able to plot them into a new band plan.
This will be a copy of the real database, so we’re working on something that we don’t have to
commit to until the end but it will mean that it gives us a chance to make sure that we’ll be
able to get everybody fitted back into the spectrum and one of my concerns - I’ve said this
before - is if your garden shed’s like mine, if you tip it all out and try to put it back in an
organised fashion, I’ll usually end up with a big pile left over and clearly we can’t be in that
situation here. We want to go the other way. We want to get to everything back in an orderly
fashion and add a bit more space for more. So, it’s quite a tall order but this tool, together
with MASTS, we believe, will bring that into reality.
QUESTION FROM FLOOR: Paul, can you go back to the other slide a moment? On the
left-hand side you have column licence and then province. That means what kind of
transmitter it is?
PAUL JARVIS: At the moment, that’s our product code we have. If it’s PMR, for example,
or if it’s administered by PBS in the RA, it’s going to be a number starting with 40, the
remaining part of the number identifies whether it’s wide area or on-site etc.
QUESTION FROM FLOOR: Is there any information in your records of what the equipment
PAUL JARVIS: No. We might have some but certainly not the detail for everybody.
QUESTION FROM FLOOR: That’s the difficulty. None of us know exactly what’s out there.
PAUL JARVIS: Yes, absolutely. I know from the industry working group that a
comprehensive list of equipment that’s in use together with the characteristics needs to be
established. We have got some but it is not a complete list.
QUESTION FROM FLOOR: I think it would all have to be inspected.
PAUL JARVIS: Yes, certainly on the major shared sites, I think you’re absolutely right.
QUESTION FROM FLOOR: Paul, on location, is that location the basis of the station?
PAUL JARVIS: Yes. What we’ve actually got here, where it says zero, it’ll be a licensed
category that can be used anywhere, a UK general type licence, for example.
When should we actually make the move? This is a few steps on, really. The rectangle on
the right-hand side here is now where we’ve moved like systems into a nice contiguous block
and the top line, again, up here, gives the detail. Now, we’ve got all the same types of user
together, so it’s all the same colour.
So, that is basically what the IT tool will do: gives us a graphic interfaced, click and drag,
users, with all the parameters into a new place and then, once we do that, it will be handed to
the MASTS algorithm to make sure that it will actually work. So, the timescales of what we
doing is October this year through to February. We’ve commissioned an independent study
on the costs to users of going through alignment. We do have the figures already from
previous work but we want to target UHF2 in detail, get a lot more factual information and
we’re at the ITT stage of that process right now.
Spring 2004: as I already mentioned, we want the industry working group to be resurrected
to look at the actual implementations. We need to also engage the shared site owners and
users because we see them as being the most complicated of all. Maybe you know different,
maybe there’ll be other concerns but from our engineering assessment so far, it’ll be the
shared sites that give us the biggest problems.
May 2004: we’ll have the basic graphic tool that we can use without MASTS and then by this
time next year, the planning tool will be properly integrated into the MASTS algorithm which
will be really when we can start doing the work that will identity precise assignment details for
people that will go through the alignment process and I know that’s a long time away and it’s
one of the areas that we’re very sensitive to, that really to give anybody the confidence, they
need to know what their future assignment will be. But when we look at the amount of work
that’s involved and the development of the software, October is the realistic time, I’m afraid.
So, then we think that we’ll have completed that work by spring of 2005 and we’ll be able to
advise all the existing users what their new channel details will be and, having gone through
the project plan process, we’ll be able to work on the timing of that. Now clearly, it’s nice to
know what your new assignment will be but you want to know whether you’ve got a week to
do it in or whether you’ve got six months and if you have to have dual running, for example,
you’ve got to look at the detail of how we can keep your continuity of service, certainly for the
big users with many, many mobiles or terminals. That’s quite a difficult issue.
The police will be returning their frequencies basically in two trenches. The first in January
2005 but even that isn’t terribly helpful until we get the whole lot back which will really be
around about the beginning of 2006, maybe even a little later than that but, nevertheless,
that’s really the time that the real work of moving people can begin. So, we start moving
from 2005. In fact, in fairness, if we do get a few applications, we look now on whether we
can put them on an aligned raster, if you like. We are trying to make new assignments on
the new format. So, basically, the on-site implementation work needs to be done between
around about the beginning of 2006 and we’d love to aim for a completion date of 2010. The
dates certainly aren’t cast in stone – but they are what we’re planning too - but the sooner we
can get it done the better because there will be a period, we know the noise floor is going to
be high, we don’t yet know how high but it’ll only settle down when everyone’s in the new
QUESTION FROM FLOOR: Lee Wiltshire, Network Rail. The date of 2010, the question
from us from our point of view, as you well know, is forwards or backwards from that date?
Are we looking at it coming forwards before 2010 or is it definitely going to go out or stay at
PAUL JARVIS: As you say, we have had discussions with both yourselves and your
regulator, as you know. The earlier the better from our point of view but your industry has
got various other drivers and constraints. Yes, as you say, the money is one thing. You’re
hopefully moving to GSMR which is rolling out, so there’s a solution for you and I think when
we get into the detailed project plan, that’s where we’ll need to work with you and, no doubt
with your regulator, to work out which is the most appropriate time. I think fortunately, in this
particular band, there are limited geographic areas that are going to give us a problem but it
means that coming from location time, we need to work closely with you. As you know,
we’ve currently agreed with the regulator that it can be towards the 2010 period but if, as
plans change and moves out, we can revise that and bring it in, great, as far as we’re
concerned but it’s the finance point of view from your side that’s pushed it to the end.
QUESTION FROM FLOOR: Paul, are there any major assumptions that you’re making
behind these timescales with regard to any Treasury process being published and, secondly,
anything to do with things like sharers lists or anything like that?
PAUL JARVIS: Yes, I suppose we have to make a bold assumption that we will get through
the Treasury process, end of the next two years and looking at what has happened for the
3.4 GHz auction which is the only other demand on the SES, .About 18 months to two years
is the realistic time to get it all unravelled, so we are making the assumption that we will be in
a position within the next two years to have the outcome of those discussions and the money
available. We’ve indicated that we’d like it before then and there is a chance that it could be,
if we don’t have to go through the over arching. If we can deal with it on this basis it could
be quicker. But again, the bold assumption is there that the money is available in Treasury.
But we have a dialogue with Treasury at the moment and they know what we are trying to
achieve; they’re supporting what we’re trying to achieve. So, it’s a case of keeping you up to
date with information as we get it.
Okay. The engineering considerations are not trivial. I know that a number of people in the
audience have actually done some work already, some quite detailed work, and we are very
grateful for the effort put in there. We know that the on site situation and the near site
situations are going to be very demanding. The intermod calculators that we have have
been developed for on site. We might have to do a few modifications for taking into account
nearby. The noise situation is another area that needs quite a lot of effort because we don’t
necessarily know what other systems are on a shared site and what the implications of the
total effect will be. And of course, putting transmitters in what’s currently a receiver area,
what sort of desensitisation will we be suffering from. So, there is a lot of effort there. I think
we need to commission some further work just to get into the detail of that during the course
of next year.
We want to go through the frequency allocations process, as I have said, from the tool.
There’s also certain sites that have got significant physical constraints. Is there the space to
put a duplicate set of equipment in, for example? Is there sufficient power there? You know,
and if there isn’t, what alternatives can we come up with to assist with the transition? So, just
about every stone you peer under, there’s a complication but what we would really love to do
is get in a position where we can all work together. We know what we’re going to try and
achieve and we all set out with the idea of trying to resolve the problems. And I think that is
a crucial thing that we all have to work for, what we hope will be - well, which will be; we
should be very positive - which will be a much better use of the spectrum and a much better
environment when it’s complete. All of that, really, looks at the sort of interference scenarios
that we are exposing the systems to during the transition period.
And then a big question mark that I know some you are aware of is the accuracy of our data.
Gerald said, “Do we know what the equipment is on particular sites?” That’s just one aspect
but it may be that we have even got the sites 100 metres out in terms of elevation and we’ve
got to go through the process of clarifying that. And one of the things that we are doing is, in
the background, at the moment we are actually looking at the effective calculations from the
MASTS algorithm and then comparing that with the levels measured by our monitoring
systems. So we can identify things that look as though they are clearly wrong. And, you
know, when we come up with those, we will be working out with our colleagues at the local
offices, the process of targeting areas that need to be visited and assessed.
So, my concluding slide here, I’m sorry I know I’ve overrun, but I think it is quite important to
go through that in some detail. We’ve got through the history of the whole project and how
we’ve got to where we are, what the drivers are for going through the band alignment
process and the fact that we’ve got the Minister’s commitment to aligning the band and then
what the consequences of those remaining autonomous are, particularly if other European
countries roll out new systems. We’ve gone through our ideas of planning the way forwards
with the development of the IT Tool and MASTS and the fact that we need the industry to
work with us and we want to resurrect the working group for all the implementation stage.
We talked about the engineering issues that we’re aware of - I’m sure there are more yet -
and the logistical issues. But most of all, I think, we are all wanting this to be a project that
benefits the UK and that it will be a success. And that’s really where we hope to work very
closely with each and every one of you. So, thank you very much.
MICHAEL SHORT: After running a little late, I think there is enough time to have a couple of
questions. So, then what I propose to do is to have the final two industry presentations then
break a little early for coffee and then have the final presentation after coffee.
And are there any quick questions before the industry views on policy are given?
QUESTION FROM THE FLOOR: Thank you, yes. My name is Tim Cull from Motorola. A
very quick question on clarification regarding the recently arrived band 415/420 as it was
proposed to be paired with 425/429. What are the implications now regarding the
developments at Fylingdales? Thank you.
PAUL JARVIS: That’s a very good question, Tim, and I think I have to say at the moment I
don’t have a clear answer. It will depend on what the base line benchmarking results show.
If we can actually continue with that without affecting the noise floor above whatever level we
agree, we will continue with that. If we can’t then we’ll have to go back to the drawing board.
So, I am not trying to evade the question, it’s just the fact that at the moment, we don’t know.
We struggled very hard to get UHF1 left as it is, basically. We’ve successfully achieved that.
We agreed that we do the benchmarking process. We agreed that the RA would take the
lead. It’s our monitoring people doing the benchmarking, it’s not the MoD or the US,
although they are working with us. That’s going on at the moment and it will go on for
however long is necessary. I have to say that because there’s no way they will ever say
when the radar can be switched off because obviously that exposes a threat. So, we have to
be there taking the slots that occur as and when. We are hoping that we’d be able to do the
complete work in two weeks. We’ve got every single monitoring system measuring the
situation in that band right the way across the UK. So, if we see results in North Yorkshire
don’t reflect what is actually happening in Leeds, we will be able to bring that to the attention
of the group that are going to set the baseline. That’s the current work and as soon as we’ve
gone through that we’ll obviously have to get it agreed by the governments, probably both
the US and the UK government. But at that point will be when it’s generally public
knowledge of what method we’ll be using to manage that band.
GERALD DAVID: Paul, the radar system proposed is megawatt and it’s polarised
horizontally. The land mobile is vertical..
PAUL JARVIS: We have seen results from the system and the monitoring systems they
have there and it does have an impact. And now, how serious that impact is, is very difficult
to interpret, from our point of view. But we are working with them. We’re trying to do our
very best to protect the UK’s position as you can clearly imagine. Our laboratory at RTCG,
which is at Whyteleafe are going to run simulations to assess the impact of radar on civil
GERALD DAVID: Thank you.
MICHAEL SHORT: We can take another person down the front. Alan was next, I think.
QUESTION FROM THE FLOOR: Alan Hudson of the FCS. You make the point, Paul, and
have done many times, that one of the benefits of realignment is the potential for releasing
3MHz of spectrum presumably by having a more orderly arrangement inside the band. I’ve
always felt nervous about that claim because I believe that the real reason for releasing that
3MHz is because you’re using the MASTS algorithm, which has not produced to date. If the
MASTS algorithm is used with the current assignment arrangement, the same benefit will be
secured. Your existing method of assignment ignores the terrain, whereas MASTS doesn’t.
So, the potential is exactly the same whether we have realignment or not. Your comments,
PAUL JARVIS: Any new assignments could take advantage of that. If we had to run the
existing systems, through the MASTS algorithm, we’d have to ask the individual companies
to define their service area and then we would still have to re-engineer to meet that so that
we could get the maximum benefit. We could certainly do that but it’s our firm belief that the
best thing to do will be to re-engineer in order to get the maximum access to spectrum in the
most effective configuration for the future, to enable all types of technology to be compatible
QUESTION FROM THE FLOOR: Jon Bental from Transcomm. You mentioned that the
Ministers had approved of this project. As a keen student of it, I can’t recollect seeing a
public statement from any minister actually making that statement. Would you care to
PAUL JARVIS: I have notes of a meeting with the Minister. I’ve got the paperwork in my
bag, it was September 2002 I think, where notes of a meeting with the Minister clearly gave
his support to band alignment. I’ll give you exactly the words because I’ve brought the
document with me. He requested that we work with industry to minimise the impact. But he
saw band alignment as the way forwards.
MICHAEL SHORT: Maybe we’ll get the reference after coffee. Are there any other
questions? If not, can we move on in the interests of time? We thank Paul for being very
open and he’ll come back after coffee with other points. Thank you.
Can I ask Alan Hudson from the FCS to step forward to give us some views and swiftly
followed by Adrian Grilli and then Derek Banner? Thank you.
ALAN HUDSON: Mr Chairman, may I start by explaining that the private mobile radio or
PMR industry, often described quite correctly as the professional mobile radio or private
business radio, will be profoundly affected by the proposal to realign the 450/470MHz band
to match the European Common Allocation table. I think it’s fair to say that the real driver
behind the table is the situation that exists on the continent where, for example, there was a
very long common border between France and Germany, with no isolation between the two
countries, whereas, of course, we are an island and we do have at the worst case, 20 miles
of separation, which is what, some 40dBs.
The PMR industry is important to the UK economy to which it contributes some £2 billion to
the gross nation product every year. It’s a mature industry that has developed over the last
50 years. There are some 54,000 licensees operating over 750,000 vehicle installed or
portable radios in 6 separate frequency bands. UHF2 is one of the largest bands in terms of
population. PMR offers sophisticated and simple mobile communication services to a wide
range of users, who for operational health, safety, security, financial or legal reasons, cannot
make use of the UK's public mobile phone networks with the limited facilities that they offer.
It’s clear to us that Mr Paul Jarvis and Mr Stephen Limb have developed a theoretical
engineering solution of some ingenuity to the complex problem of changing the frequency
assignment of all users of the band. He and his associates are to be congratulated. If the
deed has to be done, he shows a theoretical way, and no simpler route is possible if all users
are to be realigned.
The issue is, is it practical and is it doable? A risk assessment is clearly needed, as Paul
showed us very clearly today, a number of factors, which in fact could disorganise the
changeover. However, it does have serious consequences for all current users of the band
except emergency services who have the luxury of vacating it for their new airway system.
Firstly, it’s extremely expensive to implement and the current users, and we are talking about
17,000 licensees in the band, have to foot the bill from which they gain no benefits
whatsoever. The costs, of course, includes not only the engineering work to realign all
transmitters and receivers but also new hardware where old equipment’s involved which
cannot be realigned readily and new equipment at base stations, such as cavity filters, aerial
combiners, possibly even new antenna systems. There is also the heavy financial cost of the
system downtime while the work is being done. The key point is, of these 17,000 licensees
in the band, only a very small number might cause interference or suffer interference from
Secondly, there are current users who are mission critical to the UK economy and security
and cannot be shutdown at all. For such systems, the only solution would be to set up a
temporary parallel system, which would be hopelessly expensive and due to inter-modulation
problems generating interference, technically very risky. Inter-modulation problems are the
viruses of the mobile communications industry.
Thirdly, there is a shortage of engineers with the right skills for such a huge task.
Let me mention just two of the many problem scenarios. The first scenario is the two
national data networks operating with 70,000 customers in vehicles all over the UK, every
one of which will have to call at a service centre to have his equipment modified or have a
service centre engineer visit him. This process obviously will take weeks to conclude.
Synchronising the change over of several hundred base station sites spread round the
company is impossible. So, for several weeks, many customers will lose the services for
extensive periods, at various geographic locations. The financial implications for the two
operators is appalling as, apart from the loss of revenue, there are legal issues due to the
contractual commitment to provide a service at all times. These include, just for example,
users responsible for such services as cash distribution to banks and transportation of
prisoners from one prison to another.
A second scenario comes from the important public transport sector, specifically the UK
airports, which depend heavily on PMR services in the UHF2 band. Taking Heathrow, one of
the busiest in Europe as an example, with some 4,500 equipments in the affected UHF band,
providing mission critical services, there can be no question of a temporary shutdown, even
for a few hours.
The only possible solution, as I’ve already said, may be to set up a temporary parallel
system, which again is not only extremely expensive but likely to result in interference and
coverage problems that prevent reliable operation of both the existing and the temporary
system. It is also questionable whether a temporary system can even be accommodated on
the already congested base station sites and in any event, access to these sites and the
equipment, which are in use, is severely restricted in airside areas.
In today’s climate, the reliable and safe and secure operation of the UK’s airports, is a
political hot potato. I cannot think what the reaction would be if it were suggested that Paris
Charles de Gaulle or Frankfurt Airports were so treated. Again, as an on-site operation, no
UK airport can ever, now or in the future, interfere with or be interfered by a continental use
of the band.
So, why is the Radio Agency proposing to make changes, which are of no benefit to the
majority of industry? The main reason given is that without change, on a national basis,
there would be unacceptable interference between base stations in the UK, south eastern
and eastern coastal regions and base stations in adjacent similar regions in France, Belgium
and Holland. The Radio Agency makes other claims, as we have heard from Paul,
particularly the controversial extraction, almost by a miracle, of 3MHz of spectrum by carrying
out the realignment. Another claim is the cost reduction of equipment, which is standardised
across Europe. Currently, no interference of any consequence is being experienced since
the French Radiocom 2000 system was shut down. However, we sincerely believe that as
responsible people, we have to accept that eventually the Radiocom 2000 channels will be
used by other services and we must protect the UK and continental users from interference.
However, to give this protection does not necessarily mean disrupting the vast majority of UK
users, who have never and can never create or experience interference.
Mr Chairman, we need a new approach and there is one. The first task is to establish the
footprint of the area in the UK, which may experience or generate interference. This would
take into account the terrain factors, such as the South Downs and make reasonable
assumptions on antenna heights and base station transmitting power. Propagation formulas
for carrying out this task are well established and the Radio Agency has excellent technical
resources to carry out the work. The next task would be to identify, from the Radio Agency
database, the wide area, national and regional licenses for base stations inside the footprint.
Purely to indicate the possible outcome of this new approach, I am going to assume that the
footprint is only 10% of the UK land mass and has only 10% of the licensees, which as the
coastal regions in question are not heavily industrialised or populated, with the possible
exception of Dover, is a very cautious assumption.
You will ask me, why am I only considering wide area national and regional licenses and
ignoring the very much larger number of 14,000 on-site licensees restricted to 3km range?
The reason is very simple. The fact that they are only licensed for short range of up to 3km
means that their interference range is less than the width of the Straits of Dover, which is the
worst possible case. The RAs licensing statistics for 2003 show that there are only 1,475
wide area licences - that is up to 30km range - and 1,963 national and regional assignments,
to give a total of 3,438. Sorry to be so precise but -- over the whole country. Thus, taking
these figures, there are only 344 licensees operating in the footprint, using my 10%
assumption. If I’m 100% out, we’re still only talking of way less than 1,000.
So, what can be done about the 344 unfortunates? The answer is quite a lot because we are
no longer dealing with the entire licensee population of the UK, being some 17,000 users of
the band. This forum is not the appropriate place for presenting the technical options in
details for the 344 unfortunate licensees but there are at least three courses of action, all of
which use this approach as appropriate to eliminate any risk of interference. The first task is
to define the footprint, the second to identify the base station locations inside the footprint
and the transmitting power and antenna heights - all from the RA records - and the third is to
apply the appropriate technical solution. All will be expensive and unpopular for the
unfortunate licensees but it’s far better to have 344 complaints to Members of Parliament
Mr Chairman, it is good news to hear from Paul that he intends to set up the independent
technical working group again, with an independent chairman. I would however stress that
the first task of this working group should be to examine the validity of the new approach
proposal that I’m suggesting and examine it with an expert team, getting all the information
necessary to justify the three technical courses of action, which will solve the problem. The
Federation of Communication Services would wish to contribute to the work of this group in a
positive and constructive manner. Thank you.
MICHAEL SHORT: If we can now call upon Adrian Grilli to cover the utilities and concerns
from the Joint Radio Company. His perspective is with respect to the UK fuel and power
industries. And we will take questions after coffee. Thanks, over to you.
ADRIAN GRILLI: The Joint Radio Company Ltd, spectrum managers for the UK fuel and
power industries and also this morning, David Tripp is here, who does a similar job for the
water industry. One of our relevant services in the 450/470MHz band is mobile
communications, voice and data, classically PMR. Alan has already given you a proposal for
an alternative strategy in the PMR area. From the JRC point of view, we’ve been negotiating
with DTI for some years about access to the airwaves service. Of course, by the time this
goes ahead that will all be sorted out so we won’t have to worry about PMR in this band.
So, I’ll deal with telemetry and telecontrol and the presentation I’ve got says: what if? If
realignment goes ahead, what’s the implication for us within our industry for telemetry and
telecontrol? It’s a bit of a service, really. It sits there for ten years doing nothing and then as
they’ve seen in Italy, a tree falls across the line, you’ve got less than a second to do
something and if it doesn’t do it, you lose all your power. So, why bother with this service? If
you are not familiar with it, scanning telemetry is the system that we use for monitoring
networks in our industry, gas and electricity. We have a network control centre; one national
control centre for electricity and another one for gas. And that’s linked up to all things called
scanners, which are just really base stations stuck on hilltops and they talk to these
outstations. And they get back fairly basic information, 1200 bits per second, what’s the
voltage going through your transformer, what’s the current, what’s the temperature, how
much oil is there in it? If you’ve been listening recently to the problems in London, you’ll
know what data you get back . And if an alarm goes, hopefully you’ve got time to operate the
switches, reconfigure the network and it all works. Or as National Grid found in London, you
reconfigure it, someone’s put the wrong fuse in and you lose all of London. But still, that's
the point of your telemetry and telecontrol and it’s the same in the gas industry, trying to keep
these services running.
So, telemetry and telecontrol: We’ve got about 4,000 gas and electricity sites. I think there
are about 8,000 in the water sector, though David can correct me if I’m wrong there. We’ve
also got a slight problem. We’ve got 4,000 terminals on a dedicated London electricity
scheme, which runs slightly differently. But you can see we’ve got a fair number of
assignments in this band and there are more systems going on these frequencies every day.
And they have to go in on the existing frequencies. We know there is realignment. There’s
nothing we can do. They have to work to the existing scanners and the existing plans, so
we're still pushing more systems into the band as we speak and because of the concerns
about integrity of power or energy systems, there’s quite a lot going on.
Now, 24/7, you’ll remember that as the name of a company in the east of England, which
suffered a problem almost 12 months ago and low and behold, 24/7 no longer exists. It is
EDF Energy. So, I have to switch to 60/365, but the implication is that we have to have the
systems, not every hour of every day but we have to have them every minute of every day of
the year, because even on Christmas Day or the Boxing Day storms - going back a couple of
years - you need those systems there. And when your transformer’s overheating you need
to know and you need to know now. And if you’ve got a problem with your switching circuit,
for example, it’s overloading, you need to know and you need to know instantly.
Continental interference was suffered in the band, as we’ve discussed, but we had
implemented a number of engineering solutions, which means that we haven’t really had a
continental interference problem in the ST band since we did all the work for Year 2000. So,
we don’t have this problem in scanning telemetry. We’ve implemented a number of
measures to overcome it. It’s most probably not worth going through them.
And the widespread geographic deployments: We obviously are going to need to speak
quite closely to RA about that because, if Yorkshire can’t have control of their electricity
network, I suspect, knowing Yorkshiremen, they won’t be too pleased about it. We need to
operate throughout the whole of the United Kingdom.
So, for some challenging changes! If we have to go ahead with this project, we can
reconfigure some of our equipment over the air. Some of the new systems going in mean
that if Paul wants me to change the frequencies in ten minutes’ time, I just ring up Hinkley
and in ten minutes’ time they can change that frequency over the air. That can be done
relatively straightforward. Some equipment needs site visits to change frequencies. Not all
the equipment is immediately changeable over the air, for some of it, you have to retune the
So, some of the equipment does need site visits. And we start to get into the problem areas.
You can’t get onto a gas or electricity site unless you have the appropriate authorisation or
you’re accompanied by someone who has that authorisation. So, you can’t just call in
contractors. You have to have the people with the right health and safety authorisations
before you can go on site. And in one of the FCS meetings we were saying the same at
Heathrow. Before you can go airside at Heathrow to do anything, you have to have the
rights and work permits.
We are limited as to the workforce that we can use and clearly there are not that many
people who are qualified. You’ve got HSE rules. If you’re going into a live sub-station to
work you have to know what you’re doing. It’s the same with network rail. Before you can
get anywhere near that infrastructure, you have to comply with all their regulations. In many
cases we will need parallel working. The telemetry and telecontrol systems in the gas
industry have to check every minute what’s going on. So, you can’t take sites off-air while
you do it. Okay, sometimes you do lose them and you see the consequences but you can’t
plan on the basis that you’re not going to have that telemetry and telecontrol coming back.
The predominant cost in terms of changing the equipment over is labour. Going to sites, if
you think of our geographic coverage, you’ve got a scanner address in 20 sites in rural
Wales. If you’ve got to go round and change filters or even if you’ve just got to go round and
program a ROM, you’ve got to drive there, have the right keys, open it up, go through the
safety procedures, spend ten minutes doing the change, then lock it all up, make it safe and
report back to control. So, it’s the labour aspect which is time consuming. And the logistics
can be expensive if you’ve got to go round and visit all these remote sites.
Now, can I look at some of the issues because we’ve been looking at this? I was going to try
and throw Paul a bit by bringing a minute I’ve got, which referred back to one of the groups
working in 1985, but the problem is, having gone first, he managed to steal my thunder and
go back even further. But we have been working on this for a fair amount of time so we
know a little about it. If we’re going to run parallel working, we’ve got to be able to operate
on extra channels. So, we need to make sure we’ve got some spare channels. That may be
a bit of a problem. If we’re going to run them into the same sites, are we going to have a
second antenna on the site, are we going to run it through a combiner onto the one antenna,
is there space on the mast if you want to put a second antenna on there? If you were to put
in combiners and you’ve got to put in another transmitter, is there space in the cabin?
There’s the minor issue –that instead of converting equipment, you’re talking about the whole
duplicate set of equipment parallel working for the transition. And afterwards, you may have
some spare equipment but you don’t actually need it apart from during the transition. I think
Paul has mentioned, is there sufficient power in the cabin to power up all this equipment
you’re going to be putting in there?
But the key thing there that’s come out through our FCS discussions is that we’ve looked at
all these sites and thought there’s space there for us to put in a new rack or another
transmitter or we can put a combiner there. We’ve got a power supply there. But when we
talk within FCS, someone says, “Hang on a second, we’ve been marking that space to put in
our spare transmitter and you’ve talked about changing over all this site. Well, you’re going
to use your people, because they’re qualified to work on your systems. How many people
can get in an equipment room?” And you suddenly discover that we’ve said there’s a space
on the mast for a spare antenna and someone else has said, “Oh, yeah but we’ve got ideas
on putting our equipment there.” So, actually we’ve been looking at it so far in isolation. We
haven’t really been looking at it as a composite project. And as I go through this, you’ll see
that we’ve suddenly realised that most probably we’ve not been looking at the most difficult
aspect. Planning costs are there because as a spectrum management organisation, if we’re
putting in all these spare channels and extra frequencies, we are going to have to do a lot of
planning work. Lots of work for us; we’re assuming someone’s going to pay us for it.
Can we go to national co-ordination? Are all those channels available everywhere? I’m
pleased I came this morning, because I wasn’t aware of the Fylingdales issue. I noticed that
we’re at the bottom of the 450-470 band and we use 12 element Yagi antennas. I’m thinking,
“Yorkshire Electricity might have problems around Fylingdales”, because we need to use
these systems everywhere. We can’t avoid them except I suppose we can cut off their
electricity, gas and water and then we’ll see who’s eyes fill with tears first. We can get our
own back, perhaps, but there are certain services which can’t accept geographic restrictions.
We’ve got to bear that in mind when we’re looking at changing frequencies.
International co-ordination: you will notice I asked a question about that, because
international co-ordination is a nasty one. Paul has very helpfully given us the Berlin
agreement. We can’t work out what that means for us. We’ll ask him, if he can tell us what
it means for us -- but if you’re going to co-ordinate the spectrum it implies that you say to the
French, “Monsieur, you have that channel and I’ll have this channel”, and to the Belgians,
“Well, you have that one”, and to the Netherlands and to the Norwegians and to the Irish, so
that if you’re not careful, you don’t end up with the whole band across the whole area.
Because, at the moment you don’t co-ordinate, you just turn the wick up a bit if you’ve got
some problems but we’re going to have to be pleasant to them and co-ordinate. And you will
notice, from Paul’s chart, the French are keeping their cards hidden, the Netherlands are
keeping their cards hidden, the Irish are and the Danish aren’t on the plan in the first place.
So, when it comes to co-ordination, they’re already causing some difficulty. They want us to
show them our cards before they'll show us their cards. And in terms of the plan, apart from
solving this problem and, the implications, there’s the delays. If you’ve got this wonderful
plan and then some of these countries won’t co-ordinate with us, we’re going to have a
problem. It’s going to thwart our timescale and they’ve got us over a barrel.
Now, who are we going to share with? It’s quite nice at the moment. As we say, that NMT
450 being closed down. Not much of a problem. Are they using 12.5 kHz? Are they going
to want to use 25 kHz Tetra, which will not match naturally onto our 12.5 kHz channels?
What about 200 kHz CDMA, which we fear the French have in their mind? What’s that
going to do with us in terms of co-ordination when we are trying to co-ordinate 12.5 kHz
channels apart from the interference scenarios? What impact is that going to have on us?
You can either accept Alan’s point, that it only affects a small bit of the country or you can
see the charts that we had, which basically says it affects the whole of the country. This is a
problem to be looked at carefully.
Now, I don’t really know anything about intermods, I’ve decided. I certainly don’t know how
to predict them. I don’t know who is responsible for the resolution of them and I don’t know
who pays. And what suddenly struck us is that we go through in sequential fashion and
change our frequencies and then someone else changes theirs. Now, who else is on the
tower when we change our frequency? If you go onto a tower cold, then it’s your
responsibility to sort this out. Now, when I change my channel, what’s it going to do to
everybody else? I don’t know. Now, when the next guy at 450/470 changes his channel,
what’s that going to do to me? Gerald’s the expert on this and he may want to comment.
But presumably, we’ve got to look at the intermod at every stage that we do a change on a
transmitter or alternatively, change the whole site in one go and look at the intermod scenario
once you’ve changed over the whole tower. If you are doing it gradually, then my knowledge
starts to fade because it’s a serious problem, i.e. I can live with it for six months or is it going
to block the service as soon as the other channel comes on?
It has struck me that I can’t do that now because I don’t know what frequency I’m going to on
realignment and the man next door doesn’t know. I might have a problem with one of these
PMR people here but they don’t know what frequency they’re going to be on. How do I do
the intermods until we’ve all got our frequency raster? We might want to come back to that
one because it’s dawning on me slowly. And again, interference and blocking: If my
receiver’s going to be blocked, I can’t tolerate that on my system at all. I need to be able to
predict it. Before we do anything I’ve got to know whether I’m going to have a blocking
problem or not. When I’ve got the blocking problem, how am I going to solve it? But I think
one of the key things in this forum is who’s going to pay for it? Am I going to have to pay
because he’s blocking me or is he going to have to pay because he’s the cause of the
trouble? And if you ask me, it’s always him who’s the cause of the trouble and it is always he
who has to pay. So, that’s it.
I’ve reached a few conclusions. The problem must be soluble. If you’ve been watching the
BBC2 series on the Seven Industrial Wonders of the World. , it’s been fantastic. We must be
able to solve this as engineers. Let’s not be defeatist. But before we can solve them, before
you build the Hoover Dam, you’ve got to work out how to divert the Colorado River. So,
we’ve got to identify and solve these problems and solve them first. What seems to be
coming over to me is that we’ve looked at the band plan and every time we discuss it, we all
talk about intermods, spare space in cabins and power levels. I fear we are going to have to
look at it on a site-by-site basis and solve every site. Until we’ve done that, we can’t move
That’s not necessarily a big problem because the process just needs careful planning and
preparation. And it struck me because we work with the gas industry. They did this a few
years ago. Most of you are too old to remember North Sea gas conversions. We changed
from town gas to North Sea gas. Every gas appliance in the country had to be switched off,
examined, changed, modified, replaced. The whole lot had to be done. It can be done.
These industries have done it. You look at the new electricity metering arrangements, when
they moved over to competition. Every consumer in the country has to be dealt with and it
has to work. So, it can be done but it does need careful planning.
COMMENT FROM THE FLOOR: They didn’t have intermods.
ADRIAN GRILLI: No, they didn’t, but they had a lot of householders in North Sea gas
conversion. It took a little while but it was done and we all use North Sea gas now. So,
what’s gradually dawning on me as we look at the problem here is that the cost of new
equipment is the cheap and easy bit.
By way of example, Gerald has done a great analysis for us of Guys Hospital and we’ve got
Millbank Tower the other side of the river and they’re pretty close together. Now, it may be
that you’ve got to put in temporary masts and there isn’t much space in London. But on one
occasion, RA got a certain ship beside it, I think it was called “Ross Revenge”. You can use
the Thames for putting up temporary masts. If we have to have temporary masts in London
and we can’t find sites elsewhere, we could get ships. We’d put masts on them, set them up
as temporary sites. In other areas you may need to use car parks. If you’ve got to solve the
problem, you’ve got to solve the problem and there must be a solution, as engineers, but it
may cost you a bit. And obviously, what you are looking for is the cheapest solution but you
have to have that problem identified and solved before you start. You can’t go ahead and
put the RAS man in there and say, “If there’s an intermod, you’ve got to solve it because our
system’s got to work”.
We may need to look at our operating licences. Magnox Electric has to have PMR for 35km
around a nuclear station or they have to shut it down. That’s part of their operating licence.
In terms of availability and having to have systems running all the time, there have been a
few problems this summer, as I suspect you are aware, so I’ve looked at the NGT - National
Grid Transco - website. Their average availability of power over the last five years is
99.9999%. Six nines percent availability, that’s the service that they expect to deliver and we
get cross when it goes wrong. So, the telemetry systems that support that have to be
In the OFGEM report, on Birmingham, because we lost our power in London and then
Birmingham lost its power, it was interesting that the OFGEM report criticises the electricity
industry. A delay occurred in the restoration of one section of Aquila’s network, due to the
failure of a SCADA telemetry link. One failure and we’re in a Government report to say
that’s not good enough.
There are a lot more challenges but that’s enough from me. Thank you.
MICHAEL SHORT: Please welcome Derek Banner, who is Secretary General of the On Site
Communications Association. Derek.
DEREK BANNER: Thanks very much, Mike. Just briefly, to let you know that OSCA is the
On Site Communications Association, mainly manufacturers of on site equipment. The
customers generally own their own licences, and our main interest in the 450/470MHz band
is wide area paging.
But first I’d like to give a little bit of credit where it’s due. I do think that the frequency plan
that Steve and Paul’s people developed was actually excellent work. It was one of these
little games, with one square missing. But it was a magnificent piece of logistical work. And
to be fair, as well, they've also consulted the industry well. I think that’s fair comment as well.
So much for the nice guy, Paul!
Initially when I got involved with this group, I was a bit agnostic about the reversal and I think
much of the industry was. Some were pro it, and some were in favour of the reversal, and
some were very anti it. But now that people have thought through the processes and the
problems and the issues that are going to be involved - and they are vast - or in most
peoples’ estimates that I know - they are vast - we’re looking now, we’re beginning to see the
sort of practical problems that are coming out.
On a selfish note though, for in OSCA, we’ve actually done quite well out of it, because we
are already - as Paul implied - that some of the industry is already moving. All of our new
customers are now moving onto the new allocated channels outside of the band. We have
six channels, they’re all national, so we’re happy, from that point of view. However, we still
have problems with reversal, because we’ve got incumbent customers. These are mainly
hospitals who have many pagers or communications devices on systems that will have to
reverse halfway through their contracts - halfway through the life of their equipment - and
customers generally expect these systems to work about ten years. Some of the
maintenance contracts which are issued by our members are for ten years, so we are in a
window, we will have problems. Our problems are not nearly as difficult as the problems of
some of my colleagues.
We will experience substantial upheaval. We do have technical solutions, but we don’t have
financial solutions. We do see that the ‘who pays’ business as being a big problem. I’m
happy to say again that Paul did refer to that, and it was news to me that you actually are
talking to the Treasury, even though we’ve pushed the RA to talk to the Treasury, it’s good
news that we are now doing that.
The issues that I see with reversal are basically vast. I mean, it’s a bit like driving on the left
and moving over to driving on the right, but sort of doing it ‘lorries first’! Motorways first.
We’re going to have co-channel interference problems, we’re going to have intermod
problems, and I was just telling people that when I was a much younger engineer, I once
detected a seventh order intermod problem, and for Adrian’s benefit, that’s a GX7th order
intermod, that’s a lot of intermods.
But things have happened -- the problem is that we’re going to get base station transmit sites
next to, or on the same masts, or very close locations to base station receive sites. That’s
the big issue. And they are going to blank them. They’re going to be deaf, they’re not going
to work, unless we plan this absolutely to the ultimate degree. So we forewarn you there.
And also, this is going to happen in stages, so the people that are on stage three of this
reversal, are going to reverse, and they’re going to be interfered by the people who are
supposed to be changing later on, because their base sites will be on the same frequencies,
or near the same frequencies.
Adrian touched on the logistical problems. Are there enough technicians and engineers to
go around? You know, some of these sites, they might look good, but if you actually get in
them, they’re little boxes and they’ve got loads of chipware, there’s no space in them. You
can’t get more than two or three people in some of these sites. The heat that’s generated is
very high. We’ve got to add test and measurement equipment to make sure that the things
are installed properly, and when you do something on this scale, you’re going to need a lot of
test kit, a lot of measurement kit and a lot of people who are trained in using that. Filtering
devices; some of these filters aren’t small. Some of them are sort of beer barrel size, if
they’re really big filters, but those that eliminate bad interference, they’re very, very large.
They’ll have to go back to manufacturers, they’ll have to be re-tuned, you can’t do much of
that on site. And we’re not talking about a few sites. We’re talking - as Alan inferred - there
are 17,000 of these licensees. More sites, but 17,000 licensees.
For the licensees there’ll be operational problems. There’ll be a lot of disruption. You know,
Adrian’s already referred to the fact that 24/7 is no good to his industry, it’s got to be 60
seconds every minute, 60 minutes every hour, 24 hours a day, 7 days a week, 52 weeks a
year, plus the odd day or whatever. Some systems can’t go down. Some hospital systems
can’t go down. The temperature systems can’t go down. The implications of these things
going down, again, are vast.
Parallel systems might be a solution, if you have the correct frequencies to work in, but
again, in the middle of this project, you’ve got to make sure your channel has already been
turned, and it’s not in the location of something that hasn’t been reversed. So you might
have to get your parallel system out of band, and them come back in band later on. There
might be two sets of equipment you need to purchase. And also some of these operators
aren’t just taxis, where they can pop in for an hour and change over, they’re lorries. They’re
lorries on the road, they’re cash delivery people, they’re Tesco’s and whatever. You know,
these things, they’re thousands of pounds a day on the road. The operational costs of doing
that are, again, immense.
Someone mentioned the Irish question, and Paul thoughtfully said, “They might follow us”.
Well, that’s not really good enough, is it, Paul? They’ve got to do it with us, they’ve got to do
it alongside us, and they’ve got to do it at exactly the same time, when we change our
frequencies they’ve got to change their frequencies. Their usages might not be the same as
our usages, so that co-ordination is going to be - I fear - very difficult. I know you’re speaking
to the guys, and I know you’re working on that problem, but they can’t follow, it’s got to be
done with us, and we don’t have the luxury of a 20 mile Chunnel on the Northern Ireland
border. We’ve got land, it’s next door to each other. That again is an issue.
PAUL JARVIS: I’ll stop you there, Derek. One of the things that we will be talking to the
Irish techs about is so we can work with them.
DEREK BANNER: Yes, which is great. I think that’s a good step forward, and I know you’re
very open with the guys over there, but as I said, it’s got to be done with them, and when we
want to change certain frequencies, they’ve got to change those frequencies. Now, those
bands, those usages, might not quite align. That might be a little setback. But, you know,
I’m not saying it’s like -- I agree with Adrian, it can be done. If you throw money at this, throw
people at it, whatever, it probably can be done, but there’s going to be one hell of an
upheaval when it’s happening.
So in conclusion of all that, I think that the people that I know in this industry, and I include
many manufacturers in that - as well as operators - are all advising the RA against doing this.
We see little benefit for the country, and it could do lasting damage, not only to the PMR
industry, but to all the industries that operate in that band. Severe damage as well.
The funding - and it’s great news to me that Paul’s now talking to the Treasury - we’re going
to have a capital expenditure. What capital expenditure? I was speaking to Paul Smye-
Rumsby, who runs his own company in Kent, where they don’t really suffer much
interference. They did, but they don’t now. He was telling me about one reversal, which was
some years ago, which cost over £10,000 for one licence. There’s 17,000 of these licences,
yeah? There’s loads and loads of small operators that can’t pay that sort of hit. Those taxi
companies, people that run small distribution centres, or whatever, and I mean the
customers can’t take the disruption as well. So the whole industry - I’m not just talking about
the industry - but their customers are going to be greatly affected, and this - I don’t know
what figures you’re working on Paul, because that hasn’t been shared with us, the
economics of this - but our sort of ‘back of a fag packet’ type estimate is this is hundreds of
millions. Now, you say you’re going to recoup £200 million, but the cost could be hundreds
of millions of pounds.
Operational expenditure, the cost to the customer, the cost to the industry: as I said before,
lorries have got to come in and have their kit changed over. It can’t be done by anyone, it’s
got to be done by trained personnel. Base stations have got to be changed around. You
can’t just send anyone, they’ve got to be trained, you’ve got to have health and safety
people, and on many sites you can’t just send one person, they’ve got to be accompanied,
yeah? And of course, the disruption costs, which I’ve touched on. Well, we have asked the
question of ‘who pays’ and hopefully Paul will come back.
I must admit I was very disturbed today to hear that Hazel says this is going to happen. That
really made me think, and I think you’ll see there’s lots of people nodding around here, so it’s
nice to be agreed with, but when she says, “It’s going to happen”, I do think that we need that
independent working group not to work on those bounds, they must have some
manoeuvrability there to go back and say, “Look, this is a -- you know, we’ll give this a go. If
it’s a go, Paul, we will support you to the end”. We don’t want to be Luddite about this, we do
want to work with you, but to say to someone, “You’ve got to drive this through, it’s going to
happen”, when all of the industry, as far as I can see are saying, “Big problems”, I think it’s
unfair, and I don’t think it’s right.
Alan has made a suggestion. It’s elegant, it’s not cheap, but it’s not very expensive. It only
spends money when it’s necessary to spend money, and in the locations where it is
necessary to spend money, and that is not all over the UK. It’s much less costly, probably
cost just a few million pounds, and the disruption to the people, although there will be - I think
he said 300 to 400, Alan, operators who will suffer severe disruption - that’s a lot better than
17,000-odd suffering that.
We need buy in from the industry. If it’s shown to be a good thing to do, I can promise you
that OSCA will support it. I did support it, and now I have changed my mind throughout this, I
think I said that earlier on. If it’s shown to work, then I’m sure I could get buy in from OSCA.
As I said, we don’t want to be Luddite about this. I think Clear Line is a vision. I think it,
theoretically, the work that was done was very good and that worked well. But at the
moment, 450/470 does work. There’s no risk to it. People are happy with it, so why change
for what’s really quite a small amount of money - £200 million is not really a small amount of
money, is it - but it’s a small advantage to the UK, when the potential for problems and for
costs and for - literally people going out of business, losing their livelihoods - I think is very
great. I think we need to be true to that situation, we as a body, the FCS and the RA and all
the other bodies, need to be true to that situation and say, “That’s what we think, is it worth
going forward?” And if not, let’s bin it, and let’s take Alan’s suggestion - which I think is a
very good suggestion - and just deal with it where it’s necessary.
Thanks very much Mike.
MICHAEL SHORT: Okay, a final presentation before the panel, Paul’s very kindly agreed to
step in for Ade Ajibulu to cover the cost benefit analysis of band alignment. Now, don’t be
too hard on Paul as he is not an economist, but we will take questions of all the speakers on
the panel afterwards.
PAUL JARVIS: Thank you for that introduction, Mike. I’m glad you’re not going to be too
hard on me on this, because it was only 24 hours ago that I knew this paper existed and
some of it I think I’ve already referred to in the previous presentation.
The release of the 2-3MHz of yield in Spectrum, again, I know some people have got some
concerns over whether that is viable. I could very easily drop into the engineering mode
here, rather than the economics mode, but I would just like to say the current re-use is
planned on 20 re-uses throughout the UK, and that was literally just, sort of, jigsaw fashion,
so using the engineering tools available to us we know that we can make significantly more
use of Spectrum than that, and of course at some other venue - perhaps - I can discuss on
how we arrived at the 2-3MHz of yield in Spectrum. But nevertheless, we’ve got that figure,
and the common economics have been based on the fact that we do genuinely anticipate at
least 2MHz paired being released, potentially 3. But, you know, if we were to stick with the
2MHz and look at the figures there.
Of course, we do know that we’d get that reduction in interference at national boundaries
with that higher usage, and of course that, hopefully, would generate the increase in
revenue. Now it’s perhaps an appropriate point just to -- I just felt that the 10% land mass
that Alan referred to, if we went back to the reports that ST Scicon did, then we’re looking at
a significant amount more than 10% land mass.
So, maybe we need to revisit that. Perhaps we should even revisit the whole of that report.
But from my memories of working at Baldock on the investigation team, we were dealing with
continental interference issues in Birmingham and in Bedford, and places like that, where
you’d think you were fairly far enough away to avoid the problem, and it’s very easy to forget
that. But without saying that they were going to be common, it needs just first to revisit that, I
think, and one of the things I’ll take back will to have a look at the impact on that basis.
The ability to use cheaper equipment from high volume European market, that’s another area
that, I think -- what I believe is that we’ll probably be paying a similar amount for the
equipment, but it will be equipment that offers additional features and instead of you just
buying a PMR that gives you voice facilities, for a similar price - certainly for the mobile -
you’d be getting voice and data. Data and digital base stations, I think, are a different
question, and again we’d have to look at that in some more detail. Digital base stations.
COMMENT FROM FLOOR: Reverse on that one.
PAUL JARVIS: Greater flexibility from the Spectrum, I think that would be very true,
actually. If we’ve actually got this common configuration with base transmit all at one end,
and mobile at the other, then it certainly opens up the possibilities of using that Spectrum for
a much greater variety of services, if we want them, of course. So again, that’s something
from the economic point of view. Looking at the flexibility of the Spectrum or looking at
alternative services in there, it’s one of the factors that is taken into account in looking at the
value of Spectrum. And then these second order benefits; greater competition, lower prices,
there must be some detailed thinking from the economists there, and maybe if any of you
know that, then tell me. This is the danger of getting someone else to read a presentation.
From the feedback we got from the survey we did - I think it was in 2001 - the transceivers,
65% of them, were re-tunable across the UHF2 band. Now, I do need to stress here, that
was just the transceivers. Of course, as we’ve already heard, there are the filtering of the
antennas and other site considerations, but there is a belief that at least 65% of the
equipment is re-tunable, not necessarily by remote control, if you’ve got features like Adrian
spoke about, that’s wonderful, but most of them will need a visit or even taking into the
workshop to be re-programmed. But nevertheless, it can be done.
COMMENT FROM FLOOR: Paul, how many are you talking about?
PAUL JARVIS: It was - I think it was something in the order of about 17% .
However many we sent out, it would have been to all licensees. And some of the responses
were telephoned, so …
Replacing equipment that can’t be re-tuned, we do have the issue of - I did mention to
somebody over the coffee break, that whatever funding that we manage to negotiate will be
for replacing like with like, and the Treasury will certainly not entertain changing out a Morris
Minor for a Rolls Royce, so we’ve got to find some way of determining what the eligibility of
reimbursing any costs is.
So, that’s another fairly big issue for us to consider, when we get to that stage. I mean,
there’s all the other issues of space planning, and timing and everything else that needs to
be considered. And then of course, some people may decide that all this is too much hassle,
“We’ll go and have a word with Mike and see whether he can offer a different service to this
The outline CBA that Ade and his team worked up for the business case for band alignment
used the costing information from the fairly recent Spectrum review. We, with the information
we had for this band, and what I have to say is that they base figures, the sort of normalised
figure is across the whole of PMR on all the six bands that we refer to. The normalised figure
is the basis behind this, so it may be necessary again to have a look at whether there is
particular weighting, up or down, when you’re talking about UHF2, and the big problem I
have now is knowing that the rest of UHF could end up out of bounds, as that changes these
figures. And it may have done. It may have - through the Spectrum scarcity type factor - so
with that as a bit of a caveat, if we’re looking at the 2MHz figure, we anticipate that the
benefits will be £372 million, based on the figures from the survey. And the costs for those
go through with a fairly extensive realignment. Again at this very top level, generic
assessment of a typical site would be £125 million.
So, we get this overall £247 million gain, but of course you’ve got to make the investment in
years 2005 to 2010 before you see that return. So that again is something that you’re not
going to see an instant return on this, it’s as things develop.
COMMENT FROM FLOOR: Are those per annum?
PAUL JARVIS: No, no. That’s the core benefit of the Spectrum in that new configuration.
There might be a per annum, depending on what sort of services go in there, but we don’t
know whether it would be like for like, or whether there’d be new services.
PAUL JARVIS: The calculation here, as I say, is that based on this release of Spectrum we
could, if we wanted to, we could have distorted this - in a way - by adding 2 times 3MHz or
thereabouts, that will come back from the release of police Spectrum. And that will, of
course, earn more. But in theory that could be earning more anyway, even on the current
But one thing that we all have to be aware of is if we soak up that ex-police Spectrum in its
current configuration and then we find that when the Continent does roll out an alternative
system, if it then dictates that we should really have done this alignment, we’re well and truly
stuffed, because we’ve got nowhere to move. We haven’t got a little blocked space to shuffle
people around in if we do that, so we’re really entering a time, before the end of 2005, we’ve
really got to decide what we’re going to do with this band, and either go for it and decide that
we’re going to solve all the problems, or not.
I think that is the crucial thing; in my view, if we actually carrying on making assignments with
current UK configurations and soak up that spare capacity, then whatever we do, that is
almost cast in stone. If anything goes wrong with it from a co-ordination point of view, we’ve
got a real problem, as it’ll need solving quickly and affect everybody in the whole band. At
least this way we’ve got a certain amount of time - not a lot of time - but we’ve got a certain
amount of time to go through and properly think it though, and again here from the
economics point of view, the assessment of the value of the Spectrum is assuming that it’s
only one type of service - land mobile for example - going back into the Spectrum, and I’m
sure that’s what we would all expect to go back in there anyway, but if it was deemed that it
was more appropriate to have something else, then it could change these figures. And as I
say, all these figures basically have come from the RA’s economic impact study, which is
now nearly four years old. It was done in 2000.
So, the estimate then comprises the costs for re-tuning the equipment and that does include
the cost of staff and assessment of taking systems out of service, the cost of replacement of
equipment, which we’ve looked at the current market prices of equipment, and then we’ve
looked at the age of equipment in service. Some of it, in theory, would have depreciated to
the point where it’s paid its way, sort of thing, and they would be particularly difficult cases of
doing Treasury rules to get compensation, if some piece of equipment is deemed to have
had its lifetime. And of course, as I just mentioned, the service interruption, the cost - the
loss of revenue there - and look, there are various ideas in terms of that, and the big problem
is that there isn’t one solution that fits everyone. But it could be - for example - that making
more short term hire facilities available would allow not to fund everybody for a second
system, but to loan them equipment to use there during the transition. That may well work
for some, but it won’t work for all, so we need to have a look at - in a much wider context -
what alternatives would work.
MICHAEL SHORT: Okay, thank you very much, Paul. Paul, we’ll have you sit here, and
can the other speakers please step forward, and would you please direct them to the panel
as a whole? Thank you.
QUESTION FROM FLOOR: Thank you. Roy Pierce from Procom MASCS. It’s really not
directed at Paul’s last presentation, because he just made the presentation, but it’s directed
at the content.
I get rather concerned about the almost overriding influence of economists on a lot of things
that are current now, not just in our industry. We always used to say industry was troubled
by having too many accountants, now it seems to be economists. And I worry about some of
the statements in this cost benefit analysis, which sort of says things like, “Well, it’ll bring
better competition, and drive down costs”, and all the rest of it. I think there’s an interesting
parallel this week, where obviously the network rail operators decided that all this competition
isn’t very good, and they’re bringing it all back under one roof, with one contractor - or their
own contractor - and I wonder also whether, looking at some of the assumptions made, that
the costs that are estimated - I’m not arguing whether they’re right or wrong - but on the
premise that the benefits are greater than the costs. The costs have been incurred over five
years first, and then the benefits - if they do come - will come somewhat later. And if you
discount all that, you’ll probably find that in actual fact, the benefits and the costs - assuming
they are right - but taking time into account, they probably equate. So there’s no real benefit
at the end of the day.
I’m not going to ask you to work those sums out, Paul, but maybe the economist could?
PAUL JARVIS: I believe that the actual costs have been discounted to account for the time,
but that was assuming it was an even spread. Yes as you say, I cannot really answer
authoritatively any of the economic questions, and unfortunately I wish I did have a better
understanding of some of the spread. I think the other thing that we do have to consider is
the fact that most of the arguments that people are putting against it also are drawing on their
own economic assessment of their business. And somehow, we’ve got to understand how
that actually translates to the benefits that could accrue if they actually went through the
process, and then it’s the gap in between that’s got to be addressed.
MIKE SHORT: And your new study, the ITT you referred to earlier on, is that designed to
pick up more current costs ?
PAUL JARVIS: Absolutely.
MIKE SHORT: So, even if the assumptions are wrong and the economists, perhaps, don’t
understand the full ramifications of it; this new study is to get more accurate costings of the
changes for scene ?
PAUL JARVIS: In this very band, rather than the generic picture.
ADRIAN GRILLI: Mike, a couple of things relating to that; firstly, in our case Transco have
got systems which are re-tunable. What I didn’t mention is that they’re all new systems, and
they’ve optimised the front end filters, for what they think will be the new frequencies. So
they take a 1dB hit where they are and a 1dB where expected to be. They’ve engineered
them for the change-over, but if the equipment was just re-tunable, it still wouldn’t have been
good enough. They would have had to fiddle with the filers, but they’ve tried to stay one step
On the overall cost benefit analysis, what’s come out of our analysis is that there’s an
element missing; and that’s the migration cost. Two things come to mind; in our discussions
here, no one’s taken into account of that migration cost, because it’s not within the gift of an
individual company to calculate that. You have no idea what mitigation measures you’re
going to have to take, or may have to take, when it comes to the actual transition. Also we’ve
presumably worked out the simplest way for each of us to change. So we’ve worked out -
say, in our case parallel working. As soon as someone says, “No you can’t because we’re
going to put equipment in that cabin, or you’re going to interfere with us”, we have to look at
alternative scenarios, then the cost goes up.
When the electricity and gas industries moved from their old Band II systems into the
systems that they’re currently using in 150MHz, they had a suite of software developed
called Migrator, and the Migrator software and the Migrator project was solely about moving
from where they were to where they are now. That’s perhaps a cost element that the
economists need to look at, because the individual companies can’t predict those costs,
because we don’t know what they are.
PAUL JARVIS: I think it’s all very interesting. I think if we were to get the information for the
current costs to users from this study, then the intention is to have the industry working group
re-established, and I think we then need to inject the information from this into that group,
because they may well then wish to identify other areas that need to be addressed. I mean,
there’s a few things that I’d made notes of earlier on, where we ought to be doing a bit more
work in the planning stage, and I think what we need to be absolutely sure of is that we’re
working in what we believe are the right areas to study ought to be the same areas that the
industry need the information. I think that’s quite critical.
QUESTION FROM FLOOR: Mr Chairman, Brian Nicholson from AirRadio. A general
comment first, that throughout the presentations which we’ve been watching, and I was
particularly impressed, Paul, with the initial one which gave the broad view of where the
Radio Agency was coming from on this, and what it saw as the general benefits. What does
elude me still, though, is what the killer benefit is.
Which is the key one that you think is going to be resolved by this and if that - because it’s
not clear to me which it is - and if that key one proves to be not resolved by the proposed
band reversal, then would the Minister concerned be quite so keen on going forward? For
example, we’re saying here that the costs are outweighed by the benefits. If that figure
turned out to be a negative, what would be the position then, if costs were the real key killer?
PAUL JARVIS: Interesting, because I’ve had, well, a number of different thoughts and ideas
on this over the last three years that I’ve been in this job, but initially, I came into this thinking
that this is the only way we’re ever going to get digital technologies in the band. That was
my gut reaction. Then, as more and more discussions went on to what the European future
use of UHF was, the concerns of interference came back into the fore, and I still think that
that is now a very significant risk. I’m not sure whether it’s the killer, because the latest
problem on the - generic problem - with UHF with Fylingdales I think must just mean that
Spectrum scarcity in UHF is going to be the killer here, and the only real opportunities we
have are in 450/470.
Now, in parallel with the work we’re doing with the military, we’re getting them to cough up
with some Spectrum elsewhere, but that ‘elsewhere’ is not likely to be within any of the
harmonised bands, so it still comes back to the fact that if we want to try and maximise the
use of the UHF spectrum for new technologies, we want to be protected as much as we
possibly can from continental interference, we’ve only got one way to go, in my view. But
that’s looking at the information I have, not looking at the individual cost to all of your
MIKE SHORT: Can I ask a somewhat related question? There’s been a very eloquent
proposal by the FCS put forward today, and clearly if an independent implementation group
is being set up it’s quite important that it’s not excessively constrained in terms of what it
needs to do. So as far as you’re concerned, would you be happy if the implementation group
looked at that as an alternative proposal?
PAUL JARVIS: Yes, absolutely. I have no absolutely no problem with that. I think we need
to look at absolutely everything, particularly as we’ve got this transition period - if you like -
that the other European countries are in, regarding the use of the Spectrum, I think we need
to look at that. We need to look at Alan’s proposal. I think in advance of the industry working
group coming together, we’ll take away -- revisiting the ST Scicon studies and we’ll have to
look at what new technologies and typical installation these new technologies have, and see
what that changes.
QUESTION FROM FLOOR: Gerald David It’s just a short dissertation. The question of
intermods is a very important one. I want to explain, I’m speaking as myself, not for my
company. My company would love this to go through, we will sell a lot of new equipment!
So I’m speaking on behalf of my old PMR friends, who are going to be disadvantaged.
On the site you mentioned, the one I analysed for you, Guys Hospital, there are 257 base
stations. If you did the third order alone, you would take about a week on quite a large
computer, and the ones that caused trouble on 7 September and 17 September, because
you will find the bands are all inter-related. So don’t even think about trying to involve the
calculations there, they don’t mean anything. The ones you calculate will do that, but there’ll
be 150dB down. The one we hadn’t calculated would be 17dB down.
The proposal is 9dBs optimistic. It’s the RA prediction. All your site predictions are between
8 and 9dBs optimistic, which is why you don’t seem to allocate PMR on high sites any more,
and the problem the whole of the PMR industry was based on simplicity. The operator - the
controller - could only talk to his staff. The staff could only talk to the controller. He couldn’t
ring the bookie, or talk to his girlfriend or his auntie in Australia, and the difference between
the telephone in your pocket, which is a universal gadget, and PMR is simple and cheap, and
these are the people who are going to be disenfranchised. And unless we pay for it, and do
it quickly - and ‘quickly’ means within 24 hours - because you mentioned London sites.
There is not a London site that is more than a kilometre from another London site, so
therefore you have to divide because of space isolations, and you need 70. Before you can
be sure of altering the band reverse at site, you have to do a site completely.
You need to have more than 65dBs, and preferably 70dBs of space absolutely clear. The
paper I wrote, which regrettably the chairman didn’t receive, outlined the problems, which are
basically as follows; you can’t squeeze three engineers into hardly any of the London sites.
Not together. You can get one or maybe two with Spectrum analysers. The Longam test
sets are pretty small, they are 19 inch by 5U, but they’re heavy. Some of the sites - if you
recall the PMR UHF started in about 1957, it was at its peak between 1966 and 1975 - that
was the huge expansion, when ITC sold 350,000 mobiles in one year, and I think it was
The sites were an afterthought. Please don’t think that we’ve been scientific about our UHF
sites. We have been about cellular sites. This is why the cellular industry does not have the
problems with interference with intermod because they were planned. The UHF sites were
not. If you look at the sites, Guys Hospital, even Alexandra Palace, they’re shoe-horned into
a corner, into cupboards, into lift motor rooms, with inadequate ventilation, very bad access
and quite a few of them you have to climb up a ladder, a six rung steel ladder, to get to the
top floor. Now, my concern is this, that like a whale we will start this movement and it will
become stranded on a hump, because the hump will be when you’ve got a site with 35 base
stations, somebody will go sick - of the technicians you employed - and maybe one
subcontractor - one of them will go sick in the middle of doing his five base stations, and
that’s all you’d need to make that stumble. And if that site stumbles, then the adjacent sites
will stumble because they will have the adjacent band - and this is a technical bit which I
hope you’ll bear with me - nobody has mentioned site band noise. And the reason we have
two frequencies so close is largely because of base station site band noise.
The base station has a carrier, and it has to be 70dB down on the adjacent channel in the
receiver, but in the transmitter it isn’t 70dB down, even at 2MHz away. So if you have lots of
base stations on one site, unless you change them all over within the period that you’re
allowed - half an hour - I’m told by some of the major operators they couldn’t even allow half
an hour, they would only be prepared to have it off for five minutes, ten minutes.
The question is, how do you do it in the time scale, with all these difficulties and with all the
other ancillary problems, when do we get to start and who pays for it? Thank you.
PAUL JARVIS: Good question! Well, to be perfectly honest, I can’t answer that question at
the moment. I mean, the noise environment we are aware of. We haven’t called it ‘side
band noise’ we’ve just button-holed it in this term ‘noise environment’, Gerald.
As far as the logistics - and we know there is a logistics issue, obviously - we know the ones
that I’ve mentioned about space, power - you also mentioned, or I think Alan mentioned the
heat, and all the rest of it - we are aware of them, and I think that these are the issues that
the implementation group would have to address. And I mean, I know it’s very complex and
we haven’t really got that far, to work out that detail. In fact, at the moment it is still really
trying to assess what should be done, basically, and how we do it is really and truly the very
next thing that will have to follow hot on the heels.
MIKE SHORT: And I think Paul has illustrated the willingness to be flexible in terms of how it
can be handled, in the implementation group. In terms of candidates to be chairman of the
implementation group, do you want suggestions - not from the floor - but maybe in writing
afterwards, to give industry confidence in this area? Do you want any skill sets identified that
we’d like to see in the implementation group? Would those things as a submission, maybe
from the FCS, OSCA and JRC be useful?
PAUL JARVIS: Absolutely, yes. Most definitely.
QUESTION FROM FLOOR: Hello everybody, I’m Jacqui Brookes, FCS. I think you’re
probably aware, from the meeting - and in fact, people have been quite polite today, which is
unusual, if you don’t mind me saying - it’s a very politically charged issue, and I think both
you, Ofcom and the Minister are obviously very aware of that. Which perhaps is why his
statement is not in the public domain, and so it is worthwhile undertaking a rather more root
and branch analysis of the issues that people have now started to think about, once you
started to pose the question. And so I would say that the independent working group needs
to actually put its terms of reference in the public domain and make sure it engages
But when Mike introduced the whole day, he said, “We’re going from the past to the future”,
but the rhetoric we’re hearing from Ofcom is that the future is the Spectrum market, and in
any analysis going forward I think you’ve got to look at the issues you want to resolve, and
you’ve also got to take into account all the new tools, techniques and ideas in order to bring
that in, because you may find that you don’t have to harmonise, but you actually still may get
the economic benefits, the introduction of those 160 people who want Spectrum every week,
into that by doing it in a slightly different way. I mean, I think we’re on the cusp of something
quite new here, and I think it would be a very good idea to have a very much open mindset of
terms of reference in order to do that. You can bring the time scale down, rather than
rambling on committee after committee, by setting clear terms of reference and clear work
plans, and making sure that you do have studies which people can buy into.
But, you know, I think you can bring the time scale back there, but I think for everybody’s
benefit, and to perhaps to dim down the political atmosphere, you’ll need to approach it in
that way. Thank you.
MIKE SHORT: Jacqui, what we will do is to ask you to propose some terms of reference for
the industry group.
DEREK BANNER: I’d just like to make a point here, and that is everybody seems to be
talking about, “PMR, PMR, PMR”, but it’s not just PMR in this band. There’s a vast amount
of users in this band, you’ve got mobile data network, you’ve got the utilities, and all sorts of
people, it’s not just the PMRs.
PAUL JARVIS: Certainly. I think, if I could just add there, I mean one of the things that is
absolutely new to us is the impact of whatever might happen in UHF1, and I know that from
the public data operators’ point of view and many others, we’ve got to take a fresh look at
what the implications of that are, not only in the context of their operations in UHF1, but what
it might mean to the demands on UHF2, and it is so new to us we haven’t even started
looking at that aspect of the work yet.
QUESTION FROM FLOOR: Yes, Paul Smye-Rumsby, Smye-Rumsby Limited and a
member of the FCS. Paul, you mentioned fairly early on that you had presented to the
Treasury your proposal for funding, can you give us an idea of what level of funding we’re
PAUL JARVIS: Well, actually the meeting that I’ve had with Treasury at this stage was
actually to understand, from the band line point of view, what the rules were that they often
throw back at us in terms of state aid. And the big problem is that the state aid has a number
of tests - five tests - that they apply, and they’re trying to make sure that any government
funding doesn’t distort the market. That’s the bottom line. And I believe that from this
particular band, it’s very easy to demonstrate that it wouldn’t distort the market because
we’ve got such a vast and diverse set of users in there, and they would all be able to draw on
the benefits that we could negotiate.
The second angle of the meeting was the fact that to secure funding, there is a European de
minimus level, and what I wanted to understand was whether - because with the exception of
some of the very large users - whether individuals could be considered to be in the de
minimus category, because although it’s a lot of money to you and I in terms of government
funding, the de minimus level is a fair amount. It’s €100,000 over three years. So can we,
(a) deal with individual, small PMR companies under the de minimus level, or because we’re
doing this as a project to realign the band, does it have to be considered all as one? And I
couldn’t get a commitment from that, to be quite honest.
But what we have got to do is, now in the light of the other changes in UHF, is re-run
effectively, that cost benefit paper with the economists, and present that to the Treasury to
show what the costs will be, part of which are nothing to do with us wanting to realign the
band, they’re forced upon us by a government decision for another purpose.
So all that’s got to be re-done now. Then we go back to the Treasury and seek the way
forwards on how we administer the Spectrum efficiency --
QUESTION FROM FLOOR: But was the Minister made aware of this cost benefit analysis
before he said, “Go ahead”?
PAUL JARVIS: He was, yes.
QUESTION FROM FLOOR: Is there any doubt in your mind that in view of the points that
Adrian raised concerning its limitations, and its under-estimations?
PAUL JARVIS: I’m not sure as they are under estimations, I think we could actually easily
and come up with examples that would show a different angle on it. The big problem with
any of this is the fact that it was - this normalised figure - was the basis, looking at the entire
returns from PMR, right the way from low band, right the way through. Where we will be
better informed is, this ITT that we’re running at the moment we’ll be pulling up a cost
specifically for those systems in 454/470, so I think at that point, that’s were we can then re-
inform the Minister of the new situation. But it’s not only that now, it’s what the Spectrum
scarcity angle due to influences on UHF1 might have done to this.
QUESTION FROM FLOOR: And lastly, in the grand plan of things, and with the absence of
a recognisable RA, in the knowledge that such a plan of this size requires a sole source of
co-ordination, which will inevitably mean sub co-ordination, who is actually going to co-
ordinate this, and will individual licences be advised of a specific moving date?
PAUL JARVIS: My thoughts here, at the moment, are the fact that it must be centrally co-
ordinated. Okay, we’ve got to make a case for that. Ofcom, I’m sure, would want to
delegate some of this out effectively, purely because of the resource implications on Ofcom.
That said, the tools that we’re developing for general PMR management will enable Ofcom to
have central control of the data, the databases, the moves, etc. Even if other people are
actually doing it. So, my proposal that will go to Ofcom is the fact that it is centrally co-
ordinated, and it will be centrally co-ordinated with key people from the industry working
group - maybe the whole industry working group - but certainly key people from it.
MIKE SHORT: Just before we leave that, this ITT is obviously very pivotal to the reaction of
the Treasury in the next steps, do you need some industrial input to managing this selected
vendor, to make sure they have accurate costings, as opposed to them just going round
interviewing lots of people to gather them independently? Does there need to be some sort
of industrial advisory group, just on the cost assessment side; pre-implementation, for
PAUL JARVIS: That’s a very good point, because historically, getting information -
particularly from the small PMR user - has been very, very difficult, and if there is a strand
through industry where we can get to these details, that will be most welcome. And I think
what the best thing then for that will be, that the people in the audience here are specifically
invited to contact the people who win that tender.
MIKE SHORT: You’ll presumably announce the winner of that tender, say, in November, or
that sort of time frame?
PAUL JARVIS: Absolutely.
MIKE SHORT: But I did say an industrial advisory group to make sure - not that individuals
can’t have direct contact - but to make sure that they’re getting the right costings in the right
categories, so that somebody doesn’t then shuffle the numbers around and get confused.
Would that be something that maybe Jacqui Brookes, together with Derek and Adrian could
look at, and input to?
JACQUI BROOKES: Certainly.
QUESTION FROM FLOOR: Thank you, yes. Tim Cull from Motorola. A very small
comment, then a question. Obviously the short term hire people might well be able to step in
and help some of the costs associated with parallel working, which would help the cap ex
issues that you may face due to double equipment things, but that’s a decision about money,
and money is the reason of this. So my question is this; with Fylingdales, the upgrade
associated with Fylingdales, clearly now there is little or no ambiguity over whether there is
actual positive opportunity costs associated with the Spectrum that the military are now in, to
some degree sterilising and it cannot be exploited in the way that has previously been
Therefore we could expect a significant increase in fees payable by the military. Is there any
way that any of this money can be diverted to assist the realignment project?
PAUL JARVIS: That again is something that we mentioned with the Treasury, and their
immediate reaction was that any of the costs that would be added to the PMR user because
of the military use would have to be funded by the military. So you know, they’d have to
reduce their order for fighters or aircraft carriers or whatever that year to cover the Spectrum
Again, it’s our problem within the costing exercise to identify what element has been
introduced into this through the agreement to protect Fylingdales. So --
QUESTION FROM FLOOR: So, the answer is?
PAUL JARVIS: So -- well, the problem is there’s got to be now a link from the Treasury
getting the funding from the military to cover the extra costs, to diverting it into alignment.
That link is still to be made, but it certainly seemed that from the provisional meetings that
we’ve had with Treasury, that that would be a possibility - more than a possibility, that would
QUESTION FROM FLOOR: Brian Nicholson, AirRadio. Paul, just maybe thinking ahead a
little bit, where we get into implementation and we’re tackling a site or a user or whatever,
where do you think the liability would lie for liquidated damages in the event that an
implementation went wrong, and a changeover went wrong and caused operational problems
that caused significant material -- had a material impact on the customer’s business?
PAUL JARVIS: Good question, and to be perfectly honest, I don’t know the answer to that,
because I think it would depend to a great deal on how we were working with the industry to
implement. I suspect to a certain amount then, if we were still RA, then I am sure I could say
that there’d be a backdrop being under-written by the government, but as Ofcom, I don’t
know as that exists. So I think we’d need to be very careful. It might be necessary, as part
of contractors that are engaged to manage a particular site, we’d have to insist that they get
insured for liquidated damages. I don’t know. I mean, I did this as an answer to a question
on the hoof.
QUESTION FROM FLOOR: I think my answer there would be the buck would need to stop
somewhere, and whether that would be with, say, people like us as suppliers to a customer,
whether a customer would be expected to carry that risk on his own or whether the
instigators of the change would be carrying that burden of liability, would be a question I
would have in my mind, I would think.
PAUL JARVIS: I mean, I’ll certainly take it away, but I don’t know the actual answer to that.
MIKE SHORT: And I think when you hear more about the ITT, and how that’s implemented,
it’s quite reasonable to indicate ‘unknown costs’ such as liquidated damages, if you can’t
assess them. But at least Paul’s prepared to take that away as an issue.
QUESTION FROM FLOOR: Yes, Paul, once again you seem to be on the battlefront at the
moment, don’t you?
If the Minister was aware of the cost benefit analysis to go ahead, had the cost benefit
analysis shown a negative return, would the significance of band reversal have been so
PAUL JARVIS: Well, I think if it’d shown a negative return we wouldn’t have asked the
Minister to comment. There would have been no point in going to him with a negative figure,
so I think it’s not - in a sense - it’s not a question that would have arisen. The problem that I
see is the fact that we’re -- at the moment, the key driver, when this started off, was this
continental interference issue, and a lot of the work that’s gone before was all based on the
impact of continental interference on the ability for PMR - in particular - to develop in that
band, for the UK.
Now, we saw people had already put time, money and effort into engineering solutions which
coincided nicely with the systems being switched off, and we’ve enjoyed a period of quiet.
My great concern, and I know it’s the Minister’s concern, is the fact that it won’t stay that way,
and are we content that we will be able to use engineering solutions to mitigate against that
interference? Are we content that we’ll be able to make full use of the band for any of the
technologies that are likely to come on stream without going through this process? And I
think the cost benefit analysis indicated that there is a benefit. It comes out positive. It
comes out positive, based on the knowledge that we had at that time of the technologies that
could go into the band. It didn’t include the CDMA option, the UK for the moment is still very
lukewarm about introducing CDMA into that band. But if Europe does it, then the chances
are that we’ll be forced into it, at some point. And I think we’ve got to bear in mind, if we
don’t go through the alignment, it rules out any of that, and is that in itself going to be
justification without the other issues? Another strand of work for the economists to do, really.
But certainly, as far as the Minister is concerned, the cost benefit analysis using the generic
normalised figure of PMR, comes out positive. So he was aware of that.
MIKE SHORT: Okay, can I just ask a few questions of the gentlemen on my right? They’re
sitting quietly here while Paul gives these great answers. Can I just ask a question of Alan,
and it may be for Derek and Adrian to also answer this. Alan, what - if anything - do you see
as the risks, if any, of the FCS plan? Do you see it not being a risky plan? You obviously
see it as pragmatic, but are there some risks that should be at least noted that you didn’t
cover in your presentation?
ALAN HUDSON: Well, firstly it’s early days, and we have not carried out a total engineering
assessment of the plan with the three courses of technical action. But personally, I can see
that the risk is there, but low, and probably no worse than the risks assessed with the full
realignment over the UK.
MIKE SHORT: And Adrian and Derek, do you feel comfortable with that? Clearly it needs
some more development as an outline plan, but would you support that as well? I’m really
trying to give confidence to Paul that it’s not just been done on the fly, so to speak. And I
know it hasn’t.
DEREK BANNER: The data -- there are some risks, I just don’t think the risks are nearly as
vast as if we go the whole hog and turn it round for the whole country. For instance, if you’ve
got a national channel you’ve got to turn round, or give them some way of turning round
when just in the south east of England. If there’s interference. If it’s proven that there’s
interference. Roaming -- if you’ve got someone that’s based in the south east and who
travels up to London, then his equipment will be the wrong way round, effectively. So there
are some minor risks. But not really minor, to be honest, there are some risks. But it’s much
less, much, much less of a risk than doing the whole band of nationally -- yes, Alan's right,
there does need to be some sort of technical work done to that to make sure its practical -
pragmatic. But I’m convinced it’s much more pragmatic than going the whole hog and doing
a reversal for the whole country.
ADRIAN GRILLI: From our perspective as I’ve expressed in a number of forums, in terms
of PMR it’s difficult to see there being new national PMR systems. I say that from a
background of Transco just having closed down their national PMR system. We’re seeing
PMR going towards an on site, or a local type of service. Looking forward, the FCS plan
does meet the need in the environment where wide area and national PMR are becoming
less and less significant in the band. t may be that looking forward, the FCS solution is the
right solution. We’ve got to make sure we’re looking forward and not back.
ALAN HUDSON: Just on the interference issue, I saw for the first time the interesting
interference map of the country which Paul made. I’d just like to make the point that there’s
no such thing as totally interference free radio communication. There’s always some
interference. The issue is that the interference shall be at an acceptable level. Now if a
PMR user chooses to stuff his antenna 500 feet up a 1,000 foot TV mast, then it is possible
that through the process of ducting he will get interference from a very substantial distance
away. So be it. We can’t cater for everybody’s happiness. There’s bound to be a few
unhappy people around, whether we realign the whole country, as is being proposed, or
carry out the limited adjustment in the area of Kent, Essex, Suffolk, possibly Norfolk. A
limited area, we think is the pragmatic solution.
MIKE SHORT: Are there any points regarding implementation in the shorter term? Things
that you would like to see, from the audience as a whole. Are there any particular areas
where you’d like some more openness? I think Paul’s been extremely open today, but are
there other points you’d like to raise?
QUESTION FROM FLOOR: Thank you. David Tripp, CSS Spectrum Management
Associates and we fulfil a similar role to Adrian.
First of all, I’m very pleased to hear that the RA has been contacting the Treasury now with
regard to funding, because one of the things that does concern me, and it came through - to
a degree - in Paul’s presentation, was the fact that the Treasury were only willing to perhaps
pay on a like for like basis. We know in practice, and Adrian alluded to that as well, that the
actual cost of the equipment is relatively small, compared to the actual organisation - the
engineering and the changeover - and I think that perhaps in the developing processes, we
need to highlight to Treasury that you can’t just take the simplistic view of ‘like for like’. This
is a special product, this project, especially with the additional pressure that will probably
come from the virtual closure of the UHF1, so therefore if they understand that, that I’m sure
will take the whole process forward, because although it’s been done that way in the past, I
think this is a unique project. It’s a unique set of circumstances. You know, we have a whole
range of issues with regard to national interest, with regard to European interest, and longer-
term equipment development. So I think that we need, in the process - and perhaps that’s
something that the new working group can do - is to perhaps help you in developing the
reasons why the case might be slightly different, to help meet the five criteria that the
Treasury actually want to set us.
PAUL JARVIS: I think you’re quite right there, David. I think the problem that I see is that
I’ve been looking at tapping the Treasury funds - if you like - on the two levels. For some
people it will be generic to fund the whole lot, or whether it’s more appropriate to go for the
de minimus figure for the majority. I think the problem is with actually looking at including the
planning issues and the contractors, for example, that brings us fairly firmly back into trying
to write the case for funds for the whole thing. I know we’ve got to look at how we administer
that, and those other issues there. Well, I’m very alert to the whole cost of going through
band alignment, and all the different strands - not necessarily the figures - but the different
strands to it, and what I’m trying to do is to find out the most appropriate way of getting
maximum funds through Treasury, effectively.
We’re right at the very beginning of that stage. There is confirmation from the Treasury that
this is the sort of thing that the SES - Special Efficiency Scheme - was set up for. But they,
at this stage, don’t have any real feel for what figures we’re talking about, and of course the
Treasury will have constraints anyway on the total cost.
So, in a way, when we come to the implementation phase, we need to have a look at what
sort of funding will be required for the four or five years, and then get that back into Treasury
to make sure that it can be in the budget. And we’ve got to decide what we’re going to do,
how we’re going to do it, and what the costs are. And I think I’m hearing that we ought to be
looking at funding the whole thing, rather than lots of de minimus claims, which on the one
hand is an interesting case to produce, but then we’ve got a much more complex
QUESTION FROM FLOOR: Thank you, Paul. Could I just add to that? My big concern
then, really links to what Gerald was saying earlier on, that once we kick this process off,
however we set about doing it, once the process is rolling - it’s actually rolling - it would be
very, very hard to stop, and the liability issues have been raised as well at this meeting, and I
think that’s another one of these issues where it is quite important that the overall package is
centrally controlled. And you alluded to the fact that you felt that that central control was
better, and I think the overall costing, because the one thing that’s got to come out of this
cost justification and cost benefit is the actual cost, not only to the users themselves, but to
the country, if it went wrong, but also to Ofcom because there’s a large management issue
involved in taking this process. And that’s something which may not necessarily have been
completely included, because we don’t know what Ofcom’s costs are going to be.
MIKE SHORT: I think I can say for Ofcom, having spoken to Ed Richards, who’s the senior
partner there and is the acting chairman of SMAG, he’s actually very concerned in this area
of the public relations damage that could be quite widespread if it goes wrong, never mind
the costings and the other implications.
So the reason we’re holding this SMAG event is to make sure these view come out.
QUESTION FROM FLOOR: Alan Hudson FCS. Paul, could I ask you to help me
understand the Fylingdale situation? You’ve spoken in a way that gave me the impression
that UHF1, as a band, cannot be exploited any more. But surely the radar stations up in
Yorkshire somewhere - and one can understand that for a substantial area around the station
you can’t use UHF1 equipment - but surely in central London, which is a hot spot and where
the business in, you could continue allocating UHF1 indefinitely?
PAUL JARVIS: Not so, unfortunately. I do know quite a lot about the performance of the
system, which I’m not at liberty to share, but we have done some analysis with the figures
that we have, and anything basically in London on a line across to Weston-super-Mare will
fail co-ordination if it’s around about ten watts, at a typical base station antenna height. Each
one is being co-ordinated on a case-by-case basis.
QUESTION FROM FLOOR: Can I be absolutely clear about this? So what you’re saying is
that a transmitter with an antenna ten feet high in Piccadilly Circus will interfere with the radar
PAUL JARVIS: Ten feet high may not, but if it was on the roof tops it would.
QUESTION FROM FLOOR: That’s astounding, isn’t it?
PAUL JARVIS: Well, it’s total power that we have to consider, not just the single effect of
one base station.
MIKE SHORT: Before Gerald David asks his question, would you welcome - whilst
recognising this may be subject to some Official Secrets Act - would you welcome any
interference validation inputs to your Fylingdales assumption from any of the people present?
PAUL JARVIS: Well, it would be foolish of me to turn down any assistance in understanding
these things, but David Bacon has produced an assessment - the co-ordination tool - it’s
been rigorously tested by both the MoD and the Americans, and we basically agree that this
process that is a total power assessment will be -- we’ve already agreed basically that that is
the way forward. What we haven’t agreed is the levels because the level is determined by
the snapshot process.
Now, the problem is that if we take the signals as they happen to be at 2.00pm today as the
co-ordination level, then virtually anything in that line between London and Weston-super-
Mare will trip the co-ordination level.
So, what we now need to do - this is where our effort is - is try to work out how we can
specify the co-ordination level that will give us a little bit of headroom to manage UHF1. And
we haven’t done that yet. Whatever we dream up has got to be agreed by the UK and the
US government, and there is significant pressure on the UK to get some sort of MOA signed.
It isn’t signed yet, but hopefully both governments want to see that signed before the end of
this calendar year. So it’s a little early. To be perfectly honest, I have been open, I may
have said a few things that shouldn’t have been said about Fylingdales, but nevertheless we
are in a situation where we’re having to very carefully co-ordinate any further use. We do
know that there are a number of existing transmitters that Fylingdales would love to see
removed, because it’s severely handicapping their operation, and what we are minded to do
is to use those as a trade off to give us a bit of headroom across the whole band. But the
other side of the coin is, what is the impact of this new upgrade on everything that’s in
UHF1? So there’s that work that needs to be done as well.
So, I think I’ve shared that with you. You need to leave the ball in our court for us to do the
next round of work, both on the susceptibility of the radar on PMR and the other way round,
and then when we get to that stage we’ll then have to have a discussion on how we manage
the Spectrum within those constraints.
QUESTION FROM FLOOR: Gerald David My question was if the Treasury would examine
the costs that users have, and if they fail there’s going to be a rule where it’s written off down
to 5%, then they would not be considered for a cash grant ?. Now that is completely unfair
for PMR users and in fact for most mobile radio equipment, that it lasts a lot longer. And
what you’re doing is taking away their service. You’re taking away - take a small undertaker,
with two hearses and five wedding cars, he struggles to make a living, especially in the
North, and if you take away those stations he will fail.
PAUL JARVIS: Well, the Treasury themselves obviously won’t have a look at individual
cases, that will be a generic thing that we’ll have to handle somehow. But, yes, point taken.
I mean, we do know -- I think the actual C rules are depreciated over five years, and that
coincides with the notice period that is issued on that basis. But one other thing that I think is
also fair is that you can’t really plan - even if you give them that notice - you can’t plan for the
future until you know your allocation.
QUESTION FROM FLOOR: In case they try to push the five-year rule, just tell them that in
the UK, the historical counting rule is seven years for technical equipment.
MIKE SHORT: I think there’s a lot more to go with the Treasury discussions -- could we just
take two final questions, then we should really try and wrap up?
QUESTION FROM FLOOR: Just a very quick one, actually, going back to Fylingdale,
although I know it’s sensitive and everything else, but if it’s really - if it is, and I believe you
when you say this, it’s that sensitive - looking at the effect of current UHF1 allocations and
the operations there on it in a currently stable environment, is consideration, or should
consideration be given then to potential intermod product type interference that could come
when we start reversing parts of UHF2, which could spread right down through the band, and
presumably, if it’s that sensitive, become visible there?
PAUL JARVIS: Well, absolutely. I mean, we will have the commitment to manage the
interference environment from civil systems, and the impact on Fylingdales. So any intermod
will also fall into the category that has to be managed, though there’s a hope - or a wish - that
they might well occur. But let’s hope they’re in sufficiently low numbers that can be dealt with
on a case by case basis. That may or may not be true, but for the moment I think we’re
preoccupied in agreeing the broad measure levels. That aspect will have to come into the
plan for band alignment at the appropriate time. But, yes, we’ve got to protect it. We do
know that even without the upgrade, the system is handicapped by the presence of other UK
systems. Significantly handicapped.
MIKE SHORT: Can we just have a final question from Adrian?
ADRIAN GRILLI: Simply Paul, can we help you? Trying to get money out of the Treasury is
not the easiest of things in the world. It just struck me, as we’ve discussed things, putting a
few case studies in might help. On the intermod issue we had to deal with one where we had
a gas transmitter one side of the road and an electricity one on the other side. There was an
intermod between them at 450 kHz. This was Shaftsbury in Dorset, which meant that the fire
service paging system didn’t work, and they couldn’t call out their retained firemen. They
said it was our fault, we said they’re both licensed. One problem generated an enormous
amount of effort on our side, and on your side, and was obviously quite an expensive issue
to resolve. In highlighting some of these difficulties I see John Taylor at the back. Thinking in
terms of contingencies, when foot and mouth struck we couldn’t get to any radio sites to
change them, there are a lot of potential hidden costs there. We’ve got some good case
studies to help you in your Treasury case.
PAUL JARVIS: I think anything that would help us with the Treasury case would be most
welcome, on any of the scenarios. And I think what -- I mean, we’re not producing the case
for Treasury by the end of November, but maybe in the time scale between now and early
spring we can have further discussion on producing a robust case for Treasury.
MIKE SHORT: Okay, let met try and summarise some things I think I’ve heard this morning,
very briefly, and then a few thank you’s at the end. I think we’ve had a very open discussion,
which was the main objective of today. I’m very pleased, I think, that all the speakers have
brought a lot more intelligence to the debate that may not have been shared as openly as
before. I think Paul, particularly, has highlighted that there will be an implementation group
set up, where the chairman can be open for nomination, but the terms of reference can be
influenced at this stage, and certainly options like the FCS alternative plan can be
considered. So I think that demonstrates a lot of flexibility on a forward implementation plan.
In addition to that, I think I’ve heard that the invitation to tender on the costings will be pivotal,
and there is a wish and a desire to have some input, maybe on, advisory group to make sure
those costings are both accurate and sensible, because their eventual output could well be
used for Treasury input.
I think we’ve also had some good input about the willingness of Treasury to consider
contributions from the Spectrum efficiency scheme, contributions towards the cost of moving
- my words not yours – “old world” to “new world”. Clearly the precision and processes need
some elaboration, and that will take a bit more time.
I think you’ve also said (Paul) that you’re happy to look at previous assumptions, based on
some of the technical aspects, but also that the ITT on costings will lead towards some
assumptions on the net cost benefit, or net benefit to the nation.
I think clearly you’re aware of the concerns in this area, which is I think one of the key
reasons why you’ve been as open as you have today, Paul.
I’d like to thank all the speakers, though, for their contributions today. If I’ve not captured all
the actions I’m sure it will be on the tape that is being recorded of these proceedings, but can
I just ask you in conclusion to thank all the RA staff who have helped to put together today,
and indeed the speakers, for playing their part.
Thank you very much. And I gather there’s a buffet available outside. But thank you for all