Use of the 2010 to 2025 MHz Band for the Provision of 3G Telecommunications Services [8F(03)075] Hutchison 3G UK Limited (‘Hutchison 3G’) welcomes the opportunity to respond to this consultation on the use of the 2010 to 2025 MHz Band for the Provision of 3G Telecommunications Services, and draws attention to the response made also to the consultation on Consideration of Possible Frequency Plans for the 3G Expansion Spectrum 2500-2690 MHz. Hutchison 3G is the first operator in the UK to launch mobile multimedia services using 3G technology, and has invested a considerable amount of capital and effort to construct a 3G network. Hutchison 3G has an interest in all regulatory matters which concern the development of 3G, including the licensing of spectrum for 3G technology. Hutchison 3G suggests that the RA’s duty to ensure the efficient use of spectrum in the UK can be met by putting in place a stable regulatory and policy framework for allocating spectrum, one which is consistent with the requirements for use of bands which have been harmonised at a EU level. TDD technology is not in widespread use in the UK, and experience of its operation is limited. Hutchison 3G is not able to answer all of the questions raised in this consultation at this time, and has chosen not to make a response rather than respond on the basis of incomplete information. Question 1 Should the 2010 to 2025 MHz band be retained for UTRA TDD self- provided applications in self-coordinating mode? The 2010-2025MHz band has been harmonised for use across the European Union. Hutchison 3G is supports the use of harmonised frequency allocations, as these help to create a wide market for interoperable equipment. The tone of this consultation suggests that, as services are not currently being provided using TDD in the 2010-2025MHz band, this band should be refarmed for an alternative use. Hutchison 3G is currently the only operator to have launched 3G services in the UK, despite 5 operators having been licensed to do so, but that this does not imply that there is no demand for services using FDD in the 3G core band. Hutchison 3G suggests that it is premature to consider the 2010-2025MHz band for alternative uses, and would prefer that it is retained for the use currently allocated to it. Question 2 In what timescale do you anticipate self-provided, self-coordinating UTRA TDD equipment becoming available? Question 3 Do you think that demand for UTRA TDD use in the 2010 to 2025 MHz band has been affected by other licence-exempt spectrum (e.g. 2.4GHz and 5GHz) becoming available? Question 4 What are your own estimates of demand for UTRA TDD use in the 2010 to 2025 MHz band? Please indicate potential products and applications. Question 5 How long should we wait to evaluate demand for licence-exempt use before considering auctioning the band or otherwise making it available for licensed UTRA TDD use? Hutchison 3G suggests that if the band is not being used for licence-exempt use by the time that the 3G extension bands become available, then the RA should allocate and assign the 2010-2025MHz band at the same time as the 3G extension band. Question 6 Should the 2010 to 2025 MHz band be considered for the provision of commercial telecommunications services under a light licensing regime? Hutchison 3G generally agrees with the RA’s policy of reducing the regulatory burden on spectrum users. However, regulation exists to govern an individual’s use of spectrum such that other users are protected from interference. Hutchison 3G, on the basis of research material that has been published in the public domain, believes that TDD technology has a significant potential to interfere with the FDD technology used elsewhere in the 3G core band, and that regulation is required to ensure that use of both technologies is well understood and controlled. If regulation is reduced, then this may lessen the controls upon TDD users to prevent interference, particularly with respect to the power levels at which TDD equipment is operated. Hutchison 3G does not support any change to regulation of TDD which might place at risk the operation of 3G services using FDD technology. Question 7 If a light licensing regime is introduced, how should this be defined and implemented? Question 8 Is it viable for the 2020 to 2025 MHz sub-band to be made available for licensed (high-power) UTRA FDD use separately from the 2010 to 2020 MHz sub- band? Hutchison 3G does not believe that it is viable to licence the 2020-2025 sub-band for high-power UTRA FDD systems, on account of the impact that this will have on other licensed 3G operators. Hutchison 3G refers to the response to Question 6. TDD systems at high-power have the potential to interfere with FDD systems, with the result of degrading the capacity available from these FDD systems. If this change were to occur, and the data-carrying capacity of Hutchison 3G’s FDD system were to be degraded, then this would represent a diminution in the value of the 3G licence acquired by Hutchison 3G at auction in 2000. Accordingly, Hutchison 3G cannot accept such a change in the licensing environment for 3G operators in the UK. Question 9 Should the 2010 to 2025 MHz band be considered for applications on a technology-neutral basis (in particular for technologies outside the 3G/IMT-2000 family), for either licensed use or licence-exempt, self-provided, self-coordinated use? Hutchison 3G does not support the proposal to allow change of use of the 2010-2025 MHz band on a technology-neutral basis, as this is not consistent with the use of spectrum that has been harmonised according to the Harmonisation Directive. Allocating spectrum to harmonised bands yields considerable benefits for the development and operation of equipment, and it has been on this basis that the successful European mobile industry has grown. If spectrum were to be allocated to an alternative use in one Member State but not in others, the fragmentation of standards and markets would place at risk many of the benefits of the European-wide market for mobile communications equipment and services. If an alternative use if found for the 2010-2025 MHz spectrum, then this use should be agreed at the European level, by CEPT, and new standards developed accordingly. Question 10 Should the decision on the use of the 2010 to 2025 MHz band be postponed until after the frequency arrangements for the 2500 to 2690 MHz band are finalised at the end of 2004, in case these arrangements encompass use of the 2010 to 2025 MHz band as well? Hutchison 3G agrees with this suggestion, as both bands have the potential to have a significant impact upon the development of 3G. Question 11 Should alternative spectrum management models, which could be applied under a spectrum trading regime, be considered for the 2010 to 2025 MHz band? If so, which models do you consider most appropriate? Hutchison 3G believes that the most appropriate model for assignment of the radio spectrum bands between 2010-2025MHz is the model proposed in the Information Memorandum for the 3G Auction that was held in 2000. Any departure from this model will represent a change in the operating environment on which bidders for the 3G licences made their plans. The RA will be required to justify any such change and provide adequate comfort that the change does not result in any impairment of the 3G licences that were auctioned at that time.
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