800/900 MHz; Comreg starting to think strategic?

clohamon

http://www.comreg.ie/_fileupload/publications/ComReg1059.pdf

The release of the Digital Dividend in Ireland represents a unique opportunity to develop and utilise new and innovative forms of broadcasting and communications services for the benefit of users. The 800 MHz band has very favourable propagation characteristics which facilitate the provision of both wide-area and in-building coverage and the quantum of spectrum that now appears capable of release would be sufficient to facilitate the provision of high-bandwidth services to users.

In light of the expiry of two of the three GSM 900 MHz licences in May 2011 and the expected availability of 800 MHz spectrum in early 2013, ComReg notes there are a number of issues that would need to be addressed in facilitating any joint release of, and assignment of rights of use in, these spectrum bands.
Whilst it is now ComReg’s intention in principle to hold a competition for the award of 800 MHz and 900 MHz spectrum in advance of the expiry of these GSM 900 MHz licences, it notes that arrangements would be required to deal with timing issues and ensuring an orderly transition to the new circumstances arising from such a competition. In particular, ComReg envisages the need for arrangements to address the interim issues that would arise in the period between the expiry in May 2011 of two of the existing GSM 900 MHz licences and the commencement of new licences in these bands, as well as the need for arrangements that would allow all successful licensees in these bands to plan their networks and install equipment during this transitional period.

watty

Only slightly.

It's due to the Announcement by Minister regarding DTT (bealtine should have added a Digital Dividend comment and his post would not have been locked )

They have finally accepted after 10 years that pay DTT is dead.

But there is still likelyhood that they will chop up the spectrum to auction for 4 operators, and permit 3G (both crazy).

If there is ANY chopping up of spectrum for separate operators it should be 1 Fixed and 1 Mobile.
Any Mobile at this stage should be LTE only. Fixed operation can be tech neutral.

So, no I don't think this is a major shift. Just an earlier bundling of the "Digital Dividend"

What is the "Digital Dividend"?
<cynic>
Why it's the opportunity for all the EU regulators (Governments) to make as much money as possible selling off Analogue TV spectrum to Highest Bidders (inherently Multinational Mobile Operators).
</cynic>
The regulators (governments setting agenda for them), especially Ofcom have the false doctrine that highest cost for licence will drive efficient use of Spectrum and benefit consumer. Also that having multiple operators per band creates competition and thus drives down price for consumer.

While an inefficient, lazy incumbent does nothing for "good use of spectrum" (eircom has the only National Fixed Wireless Licence), soft touch regulation and "market forces" simply result in deployment of lowest Capex and highest ARPU technology deployed to benefit of the Telecom Industry, not to
Consumer, National Infrastructure, Universal Provision, Smart Economy, Important high performance services for Business etc.

A high licence cost and permitting 3G (or LTE on more than 1/3rd of band) simply ensures we have more expensive Multinational Owned Mobile that due to 800/900MHz lets them have more rural coverage without decent data capacity (fewer masts = lower capacity). It locks out Innovative local companies and the x10 to x16 better capacity Fixed Wireless solutions.

Mobile has zero install cost (only equipment cost). Fixed has an Install cost (and employs installers). Mobile even with LTE on 800/900MHz can only barely deliver broadband if there is one operator, x3 mast density compared to 900GSM and has the entire band. Fixed Wireless can deliver real broadband with less masts and 2/3rds of the 800/900MHz band. Install cost is higher, but long term benefit to consumers and business is much higher.

Even a Universal Fibre scheme needs 2/3rds of the 800/900MHz band and then for the 2% to 7% that can't even get DSL reach (repeater with min 10Mbps) of FTTC would get 8Mbps to 10Mbps minimum (not up to) . With a Mobile LTE only, the best average speed would be 4Mbps (not 100Mbps) and down to 0.6Mbps at peak time for many users (assuming 120MHz + 120MHZ FDD, N=6 20Mhz channels and one operator, with 100Mbps peak sector speed). You need that to ensure x4 performance compared to current 3G/HSPA type system).

bealtine

I think Watty is right here, I wondered about the extreme haste that suddenly struck Comreg in getting this piece out. They waited 10 years on LLU and move with all the speed of a racing slug on most things. Yet here we have an income opportunity to swell Comregs coffers and then they move so fast.

clohamon

How could you ask all operators to plan networks and "install" new equipment if there are only two licences up for grabs in May 2011. Is that not hinting at a beauty contest ? What happens to the unsuccessful ones who, having installed new equipment, lose out in the competition?

watty

There should only be one Mobile operator. The all the existing ones should be MVNOs on a wholesale network or shareholders of the Wholesale network.

Sponge Bob

clohamon wrote: »

How could you ask all operators to plan networks and "install" new equipment if there are only two licences up for grabs in May 2011.

Ehhhhh, well they could launch a band around 850mhz-900mhz before they turn off the Voda and O2 2g services and get the rest of the dividend spectrum above 900 and below 850 ( and the MMDS spectrum at end 2014 which is fairly certain)

The key thing is that this 'transition' band must be licenced as an MVNO to ensure a smooth transition after the turnoff...not that Voda ( by far the largest and easily the most IMPORTANT network in rural areas ) gets new spectrum before they turn off 2g.

Were everyone to think that their phones wiill stop working next year :D:D:D

clohamon

Silicon republic interview with Alex Chisholm. Still no hint as to how many licences in total.

ComReg and spectrum rollout

This brings us on to the subject of spectrum and digital dividend. ComReg, he says, is seen as a pioneer driving spectrum rollout because of its geography, low population density and low military dependence on spectrum. The opportunity is to use the abundance of wireless spectrum to drive investment and create jobs.

"What has been critical is the spectrum available sub 1GHz. What is significant is that it is the sweet spot between how far you can go with spectrum from a propagation point of view and how much data you can carry over bandwidth. To be able to bring mobile broadband services of serious speed right across the country that spectrum is important.

"At the moment that spectrum is being used for two purposes: 2G, which most people in this country still use for mobile purposes, and secondly for television broadcasting, which is analogue at the moment at 800Mhz.

"What we've been working towards these last two years is to liberalise the spectrum for 900Mhz so that it wouldn't be used for 2G voice telephony but also for broadband. We have mobile broadband that is at 2.1GHz - to enable that to happen at 900 or 800Mhz will reduce the costs involved in providing fast mobile broadband across the country."

Chisholm says the confirmation by Communications Minister Eamon Ryan TD that analogue TV services will be switched off in 2012 is giving certainty to the mobile operators and could put Ireland in the front ranks of European development.

"We didn't have that certainty before so it is significant," adds Chisholm, pointing out that because there is unlikely to be another digital terrestrial TV (DTT) provider other than RTÉ in 2012, that means more spectrum and more broadband.

"Up until earlier this year we thought we might have been one of the last in Europe but with this new development we'll be up amongst the leaders when 800Mhz comes available which will be 2013."

watty

One is the correct number.
They need to combine with the 872 to 960MHz GSM spectrum (Digiweb also has 4MHz + 4MHz in this band).

Two licences (one Fixed, one Mobile) at most.

Mobile is terribly inefficient, even at technology that is theoretically perfect, you need about 120MHz + 120MHz FDD Minimum (N= 6)and higher mast density than existing GSM uses to be able to deliver the capacity to avoid congestion. Even then you are only at "entry level" broadband speeds (1Mbps to 3Mbps). Not at 15MBps + speeds, which will soon be "entry level" on UPC.

GSM still has 1800MHz.
With 3G on 2100MHz.
If there was a plan, the masts on 900 could all be converted to 1800 GSM by start of 2013. Analogue switch of is 31st December 2012
Then give the existing Mobile operators wholesale access to a shared RAN with short term discount for those giving up 900MHz.

You can't do it piecemeal as there would not be the spectrum to reuse channels in cells properly. To totally avoid interference, especially on long travelling sub 1GHz and have no holes in coverage.

The entirety of 900MHz (all GSM operators + digiweb) is only 88MHz. This can be perhaps extended a little at 960MHz to 972MHz.

The 864 to 872 includes two guards and has licence free gear. Stacks of it. So that can't be touched. Use that as the Duplex guard band for LTE


If we make the 960 upper limit of 900MHz be 992MHz instead of 960, then for LTE downlink we can have 6 x 20Mhz channels 872 ... 992MHz and for LTE uplink 5 x 20MHz channels 744 ... 864MHz.

So to do LTE properly you need ONE RAN operator, and ALL the 900MHz GSM spectrum + 32MHz extra above GSM!

Also 744 ... 864MHz from TV, plus a guard of 2MHz = 470 ... 742 MHz (exact number of 8MHz channels)

A single LTE 20MHz "100Mbps" sector across the cell area only gives a sustained throughput of 8Mbps to 12Mbps shared between the active users. (4 to 8 time better than 5MHz HSPA). The 100Mbps only applies to a single user connected with perfect signal. With N=6 you can have more overlap of sectors and thus nearly twice the capacity. With N=6 you can roughly have an average of 60 users active per mast with sustained speed on average per user of 1Mbps if all simultaneously downloading.

Having 4 operators with N= 3 x 5MHz channels is 60MHz + 60MHz rather than 120MHz + 120MHz and would give 1/8th of the capacity per operator! A much more uneven experience. Lightly loaded it would be identical to 3G/HSPA and heavily loaded about twice as good as 3G/HSPA.

clohamon

That all looks like sense, but was the underlying technical argument ever put to Comreg in this set of consultations?

The written submission made by IoffL dealt primarily with the rearrangement of the blocks and didn't deal with the technical reasoning for having wider blocks or one block i.e. the inherent problem with mobile 'broadband' that's explained forcefully and often on this forum.

If Comreg disagreed with IoffL's reasoning on technical grounds they should have been made to say why. Even if they didn't wish to engage on the technical argument, a submission from IoffL would at least have prevented them from claiming that it was never made. I suggest that it should be made (or re-made) to Comreg.

Comreg alluded to the IoffL submission in Section 6.10 of Submission 09/99 (and later)

Making 900 MHz spectrum available in block sizes of 2 × 10 MHz as opposed to 2 × 5 MHz.
ComReg notes that this option was considered and addressed in Section 7.4.2 of Consultation 08/57. This respondent did not respond to Consultation 08/57 and in its response to 09/14 it has provided no information not previously considered.

To recap, here is 7.4.2 from 08/57

7.4.2 Spectrum Block Size
In determining the minimum appropriate spectrum block size for the future release of spectrum in the 900 MHz band, ComReg has had regard to the following factors:
• the need to make spectrum available in blocks that would not unduly limit the efficiency of wide band technologies capable of operating in the band;
• the need to make spectrum available in blocks that would not unduly limit the number of licensees in the band – thereby facilitating the development of competition and maximising the benefit for end users; and
• the benefits of keeping future competition processes simple and transparent.
In considering the minimum appropriate block size that would not adversely affect the efficient management of the radio spectrum, ComReg has focused its analysis on the systems currently identified in the draft EC decision, in particular:
• in the case of GSM technology, the minimum appropriate block size is 200 kHz or a multiple thereof; and
• in the case of UMTS900, the minimum appropriate block size is 5 MHz or a multiple thereof40.
ComReg therefore considers that assigning spectrum in blocks of 2x5MHz (or combinations of such blocks) is the optimum means to accommodate the technologies currently identified in the draft EC Decision.
In the interests of maximising the flexibility of future spectrum assignments, ComReg has also considered the implications of a range of alternative systems, not currently listed in the Annex of the draft EC Decision. Some of these systems can be deployed in channels of less than 5 MHz. However, adapting the minimum block size to these narrower bandwidths would lead to varying degrees of spectrum becoming unusable if the technologies currently listed in the Annex were to be deployed.
Similarly, some future wideband systems, currently in development, may require channels exceeding 5 MHz. Adopting a minimum spectrum block size in excess of 5 MHz would unduly limit the number of potential licensees in the band, thus reducing the potential competition for consumers (see Annex F).
The specifications of the wideband systems currently under development may be subject to further change, but analysis indicates that these systems can operate in blocks comprised of multiples of 2x5 MHz resulting in a minimum of unused spectrum.
In light of the above factors, ComReg considers allocated blocks of 2x5 MHz to be appropriate when making spectrum available in the 900 MHz band, as this size represents a reasonable balance between facilitating the maximum number of licensees in the bands and maximising the efficient use of the radio spectrum.

With technological neutrality and abundant spectrum none of the above reasons are still valid except perhaps the possibility of unused spectrum.

Auction vs Beauty Contest

With the addition of the 800Mhz band, two of the factors which underpinned the decision to allocate the spectrum by auction are gone ; namely scarcity and fairness.

As there is now more spectrum available than the MNOs were looking for, it seems also that the 'efficient allocation' argument is weakened too, and with an abundance of spectrum an auction would also probably bring in less fees as under the DotEcon analysis. ; both the reserve and the minimum price/Mhz would fall.

All of that taken together; there seems to be a good case for changing to a beauty contest and presumably a fourth consultation. If that happens then it will be even more important that the technical argument above be made.

watty

Comreg will auction to 4 Operators and it will be no better than Current 3G.

clohamon

watty wrote: »

Comreg will auction to 4 Operators and it will be no better than Current 3G.

Maybe they will, but both O2 and Vodafone have claimed that they have the right to have their licences renewed solely on the basis of "demonstrated need".

They have both put in lengthy submissions on this claim, citing a statement by the ODTR, legal principle and precedent. Comreg are therefore on notice that they face a trip to the high court if they attempt to auction the spectrum without first securing a renewal for these two.

Logically it would seem a better bet to try to injunct the auction than try to have it set aside afterwards, particularly if one of them succeeded at auction and the other didn't.

Time is getting short until the licences expire. If a legal challenge is in prospect Comreg will at least have to put in place interim arrangements until Vodafone's and O2's claimed expectations have been dealt with in the courts.

Getting back to the consultation. Comreg invited those who had made submissions to discuss them face to face. It seems IoffL didn't take them up on that. Was there any particular reason for that?

bealtine

clohamon wrote: »

Maybe they will, but both O2 and Vodafone have claimed that they have the right to have their licences renewed solely on the basis of "demonstrated need".

They have both put in lengthy submissions on this claim, citing a statement by the ODTR, legal principle and precedent. Comreg are therefore on notice that they face a trip to the high court if they attempt to auction the spectrum without first securing a renewal for these two.

Logically it would seem a better bet to try to injunct the auction than try to have it set aside afterwards, particularly if one of them succeeded at auction and the other didn't.

Time is getting short until the licences expire. If a legal challenge is in prospect Comreg will at least have to put in place interim arrangements until Vodafone's and O2's claimed expectations have been dealt with in the courts.

Getting back to the consultation. Comreg invited those who had made submissions to discuss them face to face. It seems IoffL didn't take them up on that. Was there any particular reason for that?

Comreg have already decided what they will do all "consultations" are just a smokescreen to deflect attention.