World Radiocommunication Conference (WRC 12) Intellect Response February 2010

Russell Square House T 020 7331 2000 10-12 Russell Square F 020 7331 2040 London WC1B 5EE www.intellectuk.org

Information Technology Telecommunications & Electronics Association

Contact: Henry Parker T 020 7331 2019 E [email protected]

About Intellect

Intellect is the UK trade association for the technology industry which comprises the information and communications technologies (ICT), electronics manufacturing and design and consumer electronics (CE) sectors, including defence and space-related IT. We are formed by 780 Small to Medium Sized Enterprises (SMEs) and multinational member companies with interests in these sectors and exist solely for their benefit. Over the last 12 months, we have hosted 550 meetings attended by 3,486 people visiting our London offices and hosted 60 events for our member companies. 3,900 delegates have attended conferences we have organised in the past year. The industries that Intellect represents contribute at least 10% of the UK’s GDP, employ approximately 5m people and contribute £120 billion to the UK economy.

Some of the companies involved in our work in relation to spectrum allocation and licensing are shown in Annex One to this response.

Question 1: Are there any opportunities or threats associated with WRC-12 in addition to those already identified in this consultation? Do you agree with the prioritisation of the agenda items, and if you have identified any opportunities or threats, does this have an impact on these priorities?

Intellect believe that have captured the threats and opportunities associated with WRC-12 correctly, in the sense that most (if not all) of the variable (as opposed to the standing agenda items) create both threats and opportunities for stakeholders engaged with radio communications. Whether the proposals under a given item are a threat or an opportunity depends very much on which stakeholder you engage with. In producing this response, Intellect believe we are in a unique position, in that we are able to collate the interests of both terrestrial and space based wireless services from a commercial perspective. It is also noticeable that that the community of member companies that have produced this response comprise both large multinational companies, who participate in some of the existing Ofcom/Industry forums discussing WRC’s, as well as range of Small to Medium Sized, and micro-businesses, with whom Ofcom may not have engaged at all on this topic. We understand that this consultation has been initiated with this objective in mind.

Question 2: Do you have any comments on the mechanism for UK preparation for WRCs and the role of Ofcom in this process?

As indicated in the consultation document, the formal responsibility for the UK preparations rests with the UK Spectrum Strategy Committee and the IFPG, chaired by Ofcom, has delegated responsibility. With this structure, there is a need to clarify and potentially review the policy objectives on which the UK positions should be based.

The basis for UK positions on WRC issues is often unclear. Ofcom’s policy objectives are based on maximising benefits for the UK citizen and consumer1, but in the global regulatory forum of the World Radiocommunication Conference, changes to Radio Regulations have, at most, a very indirect impact on UK citizens and consumers of radiocommunication services. In contrast, the impact on UK industry may be much more direct and significant. Successful UK industry benefits all UK citizens through its contribution to the UK economy, and yet policy objectives related to the support of UK industry seem to be missing from the UK preparatory

1 Given in the general duties of Ofcom in the 3 (1)

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process.

For several sectors of UK industry, the outcome of WRCs has a significant impact. For example the aviation industry, the HF broadcasting industry, the satellite communications industry and the space science industry all rely on internationally harmonised frequency arrangements in the Radio Regulations. For some other industry sectors, such as the terrestrial mobile industry and domestic terrestrial broadcasting industry, internationally harmonised frequency arrangements are highly beneficial even if they are not an absolute necessity. Changes to the Regulations can, and often do, have a positive or negative impact on these industry sectors. Ofcom’s own figures note that in 2005/06, the estimated economic benefit arising from use of spectrum was £42 billion2. There is every reason to believe that this total now far higher, especially given the growth of data communications using wireless.

It is quite apparent that many other countries determine their national positions for the WRC giving strong weight to the requirements of their industry. It is also apparent that Ofcom is reluctant to give consideration of the benefits to UK industry, even on issues where the effect on UK citizens is minor or neutral. This places UK industry at a disadvantage compared to industry in other countries. Intellect has supported the relevant provisions of the Digital Economy Bill related to the encouragement of efficient investment in infrastructure, currently before Parliament, with these views in mind.

Intellect suggests a review of the general policy objectives on which the UK positions should be based, with stronger emphasis given to support of UK industry objectives. We believe we provide a technology and commercially neutral forum to determine these objectives and would be pleased to assist Ofcom in any such review with these attributes in mind.

Question 3: Do you agree with Ofcom’s view that WRC-12 does not have direct implications for equality or diversity of UK citizens?

Intellect concurs with the Ofcom view in relation to this matter

Question 4: Do you agree with Ofcom’s view that it is beneficial to identify spectrum for ENG use on a non-exclusive basis in order to support market-led, non-mandatory harmonization?

Intellect supports Ofcom’s views on Agenda Item 1.5, that any identification of spectrum for ENG use should be on a non-exclusive basis and that the objective of such identification should be to provide a tuning range for ENG equipments within which different sub-bands are likely to be available in different countries.

Intellect also understands Ofcom’s view in favour of a market-led, non mandatory harmonization of spectrum and strongly believes that this could be best achieved by the current Method 1 of draft CPM text with the rationalization of frequencies for ENG use through the creation of a database of frequencies used in each country for ENG. This method would require no change to Article 5 of Radio Regulations and would provide foreign newscasters with the needed information to ensure that they deploy with equipment that will operate within a given country and allow broadcasters to seek approval for spectrum use. It will also provide manufacturers with a knowledge base of required spectrum parameters that will enable them to build common-use equipment that will leverage economies-of-scale for the worldwide ENG market. Indeed, Intellect notes that equipment for ENG are usually

2Ofcom Report: The economic impact of the use of radio spectrum in the UK

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designed for operation over a large frequency range (on a tunable basis) with hardware filtering for the whole operation band (rather than a specific operation channel). Therefore, economies of scale and ease of circulation of equipment for ENG can be obtained through this market led approach, rather than through harmonization of specific frequency bands to be available across regions/countries.

Furthermore, Intellect recommends the following:

• Spectrum identification should not constrain or jeopardise the usage of spectrum already harmonized for the development of new and innovative services. A good example is the L-Band: a CEPT-wide harmonised spectrum band (under the Maastricht Agreement) for mobile multimedia services that are incompatible with ENG operation as several contributions to CEPT studies are recently demonstrating.

• Ofcom to oppose the inclusion of already harmonized spectrum (such as for example L-Band) whenever this could be constrained or jeopardized by potential ENG use.

• Spectrum identification process for ENG use should consider co-existence studies with potentially impacted services in order to avoid disruptions and Ofcom to oppose from the potential candidate identified spectrum for ENG use, that spectrum that does not satisfy the previously mentioned criteria (for example the L-Band).

• Spectrum identification for ENG use should be as wide as possible and take into account professional vs. non professional use to have a future proof solution and allow each country to select the most appropriate frequency sub-band for ENG operation, depending on services deployed on a national basis and local market condition. • Support Method 1 of the draft CPM text as the best approach to achieve and support Ofcom’s view for a non exclusive non mandatory spectrum identification for ENG use.

Question 5: Do you agree with Ofcom’s aim to seek an appropriate regulatory framework to facilitate the development of fixed service in the bands above 71 GHz

Intellect concurs with Ofcom’s intention promote and facilitate use of spectrum above 71 GHz by fixed services. It is important that in seeking to promote an appropriate regulatory framework, Ofcom ensures that it takes into account the requirements of other services operating above 71 GHz. We also believe that in the course of promoting a given framework under this agenda item, Ofcom should ensure that there is no intention to extend the frequency allocations to fixed services.

Question 6: Do you agree with Ofcom’s intended approach to use of the band 21.4 – 22 GHz?

Intellect agrees with Ofcom that flexible use of the 21.4-22 GHz band is critical for the successful deployment of satellite systems. Proposals in support of a priori planning restrict access to spectrum (note the under usage of AP30B Ku FSS spectrum) and prevent technological developments. Intellect also opposes the concept of ‘queue jumping’ that is proposed by some administrations, a concept that would essentially allow a new filing, made at any point in time, to move to the front of the satellite network coordination request queue.

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Satellite operators depend on certainty with regard to the filing status, allocation and availability of spectrum at a given orbital position prior to undertaking the significant financial commitment required to build and launch a satellite. The current filing process for satellite spectrum allows satellite operators, in tandem with their filing administrations, to fully evaluate coordination requirements, particularly once individual filings (Coordination Requests or related AP30/30A applications for planned BSS spectrum) are published by the BR. Further, principles such as “queue jumping”, once established in the Radio Regulations, would set a very dangerous precedent for the assignment of all satellite spectrum and undermine the stability of the present system.

Further, Intellect sees a need to ensure that there is adequate feeder link spectrum available for the 21.4-22 GHz band. A review of the uplink spectrum to support all of the downlink Ka- band spectrum (e.g., BSS and FSS spectrum from ~ 17.3 GHz to 31 GHz) reveals that there is insufficient spectrum to meet the requirements for Ka band satellites. The bands highlighted by Ofcom—17.3-18.4 GHz and 47.2-49.2 GHz—should certainly be evaluated in this work. Intellect asks that Ofcom keep in mind that the existing frequency bands may not be feasible because of their use for uplinks for other satellite frequency bands, or if they are already heavily used by other services.

Question 7) Do you agree with Ofcom’s approach to the sharing issues in the band 790 – 862 MHz?

Intellect fully concurs with the Ofcom view that the digital dividend, and ensuring that potential for interference with any services operating in it, is of key of importance to UK citizens and industry. We have noted and support moves to harmonise allocation of the digital dividend across EU member states, and we believe the best use of the band (in terms of direct contribution to the UK economy and introduction of innovative new services to consumers) lies in allocation to mobile networks and, in particular, mobile broadband. Ofcom’s effort to ensure that the possibility of deploying mobile networks in this band is not limited is therefore very welcome, and we hope will ease the path for introduction of these services.

Within this context, we believe that sharing studies underway as a result of Resolution 749 of WRC-07 should be continued and Ofcom’s active involvement assured. In doing so, we believe that Ofcom should ensure that discussions that involve compatibility between services only in one country are outside the scope of discussion of Agenda Item 1.17 at the conference itself. Such discussions would not be reflective of the overall intention of the studies themselves, which are after all intended to mitigate potential cross border scenarios.

Similarly, compatibility studies on adjacent bands (i.e. below 790 MHz and above 862 MHz) should be out of scope of any discussion on this item, whereas adjacent channel compatibility should be within it. Finally, compatibility studies involving only mobile service technologies should also be out of scope. It is our view that again, such studies are not relevant to discussion of the item as a whole, focused at is it is on mitigating the potential for interference between mobile services and other services currently using the band, including terrestrial television, radio-microphones and aeronautical radio-navigation.

Question 8: Do you agree with Ofcom’s objective to protect the existing services from deployment of HAPS?

Intellect agrees that Ofcom’s primary focus in considering this item should be protection of existing services. These should include conventional fixed stations and fixed satellite space

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stations. Within that framework, we believe that sharing studies around use of HAPS in the range 5850-7075 MHz should continue.

Question 9: What is your view on the need for additional spectrum to be allocated for mobile satellite services?

The mobile satellite industry has enjoyed many years of growth and has been a success story for the UK: both in terms of satellite operators and satellite manufacturers. The UK government has recently recognised the importance of the UK space industry with the establishment of the New Executive Agency for UK Space and Satellite Industry, citing in particular the contribution made to the UK economy by the UK space and satellite sector3.

To maintain the success, the mobile satellite industry needs to adapt to the needs of its users. Just as broadband is driving growth in the terrestrial mobile arena, broadband is driving growth in the mobile satellite arena. Access to broadband in the home and when travelling is becoming a necessity for many consumers, and there are many locations where broadband access via satellite means is the only option to provide ubiquitous mobile broadband. There will undoubtedly be a need for new broadband MSS services in the near future and it is apparent that the current allocations for the MSS are not sufficient to meet this demand. The availability of spectrum to accommodate the growth in MSS is vital and hence Intellect supports the need for additional spectrum for the mobile satellite service.

We recognise that the frequency range 4-16 GHz is well used by a variety of services and anticipate that new MSS systems would be required to co-exist with existing services and systems.

Question 10: What are your views on the spectrum needs for the control of unmanned aircraft?

Intellect believes that there is considerable potential for Unmanned Aircraft Systems (UAS) to be a real success story of UK expertise and innovation. There has already been extensive investment in product development, and facilities in devolved regions, that will promote these capabilities. A notable example is the Parc Aberporth UAV centre which has attracted over £30m of public investment. As we highlighted in our response to the Ofcom Consultation The way forward for the future use of the band 872-875 MHz paired with 917-921 MHz, UK investment in non-military UAS already amounts to approximately £40m and there is potential for the UK to benefit from a 15% share of what could be a $38bn global market over the next ten years if the right conditions are put in place for UAV development, including harmonised spectrum allocations. International harmonisation of spectrum allocations would simplify designs, reduce costs, and underpin a growing export market for UK technologies. Bands of interest to our members include 920 MHz, 4.3 GHz, ~5 GHz and 15.5 GHz. It follows, with the growth of this market, that additional spectrum allocations should be promoted.

In this context, Intellect concurs with Ofcom’s view that studies to determine technical descriptions, which we assume include the spectrum requirements for safe operation of UAS should be continued. We also note Ofcom’s view that where possible harmonised allocations should be introduced in spectrum already reserved for aeronautical use. Ofcom should however note that in order to ensure the unmanned aircraft in European airspace can be safely operated, 34 MHz of terrestrial and 56MHz of satellite spectrum are required to provide ATC relay, C2 and SAA services. Ofcom should also note that the bands identified for AMS(R) S

3 see http://nds.coi.gov.uk/content/detail.aspx?NewsAreaId=2&ReleaseID=409485&SubjectId=2

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in No. 5.357A are not large enough to accommodate the projected future UAS requirements and therefore other frequency bands will be required.

Question 11: What are your views on the technical and regulatory issues related to new aeronautical services? Is there a current or expected future demand from other services to use the bands identified under agenda item 1.4?

Intellect concurs with Ofcom’s approach to this agenda item.

Question 12: What are your views on the use of the 1.6 GHz bands by MSS?

Agenda item 1.7 is linked with the EU Single European Sky initiative (SES). The objectives of the SES and more particularly the SESAR (Single European Sky ATM Research) aspects are supported by Intellect. The work to define SESAR is currently in progress and may involve increased use of the satellite systems to carry the ATM requirements, as envisaged by the ESA IRIS project. This may lead to increased requirements for AMS(R)S spectrum assignments in the 1.5/1.6 GHz MSS bands.

Intellect also recognises that the 1.5/1.6 GHz spectrum which is considered by this agenda item is well used by existing MSS operators and Intellect supports the continuing use of the 1.5/1.6 GHz bands by those MSS operators. There is therefore a need to balance the confidence of spectrum availability for future AMS(R)S projects such as IRIS on one hand with the need to ensure efficient use of highly congested spectrum on the other hand. The current regulations for ensuring priority access to spectrum for air safety services have worked to date while allowing efficient use of the spectrum. Intellect considers that the current regulations are satisfactory for current and future requirements.

The current congestion and the anticipated new demands in the 1.5/1.6 GHz MSS bands indicate the need for additional allocations for MSS. These should be considered along with the requirements arising for UAS (agenda item 1.3) and general MSS (agenda item 1.25).

Question 13: What are your views on the Appendix 17 frequency arrangements for maritime use?

Intellect supports a revision of Appendix 17 to facilitate the use of new digital communication systems, whilst maintaining sufficient provisions for remaining operational requirements involving Narrow Band Direct Printing (NBDP) within the GMDSS. We are also of the opinion that any changes to Appendix 17 could be implemented within a certain transition period.

Question 14: What are your views on the need for additional allocations for maritime mobile use to enhance maritime safety and security?

We appreciate that Ofcom has been promoting this item as the UK delegation. At the same time, there is a need for Ofcom to recognize that ongoing studies have not universally proved the case for such additional allocations4. In the view of Intellect, Ofcom should reconsider its views in relation to this item until these studies are complete. Fellow member-states of CEPT

4 These include those around the satellite detection of AIS, taking into account Resolution 357 as adopted by WRC07, the possible harmonization of technology for cargo identification and tracing through ITU Recommendations, the broadcasting of security levels for ports and coastal waters in the band around 500 KHz and the harmonised introduction of new technologies by the maritime mobile service (in the VHF band) through possible regulatory measures (Resolution 342 Rev. WRC 2000)

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are of the view that additional studies are necessary in order show conclusively that a change to the Radio Regulations is warranted in this case. Intellect is inclined to agree. This is particularly so in the case of any revision to spectrum allocation tables. The introduction of new technologies that promote maritime and security applications are of course supported by Intellect in principle. But our current view, dependent on the outcome of the studies cited, is that such introduction should be possible without such a revision of the Radio Regulations. Furthermore we believe that such further studies should only be conducted following provision of information that clearly demonstrates a lack of available spectrum to support these applications. With specific regard to RFID, studies and any allocation should ensure that the unusually high power interrogators likely to be needed in do not lead to harmful interference.

Question 15: Do you agree with Ofcom seeking to protect services operating in the UK from any impact due to long range VHF radar systems?

Intellect understands that the original proposer of this Agenda Item is known to have far wider applications than just civil or scientific ones. Intellect concurs with the Ofcom view that extensive technical studies are necessary to ensure compatibility with existing services in and adjacent to the candidate portions of the band 30 MHz- 300 MHz (and key harmonics thereof), in particular those used by the Ministry of Defence. Nevertheless, we do not believe that Ofcom should rule out such technical studies that assess implementation of new allocations for radiolocation service in bands within this range. Ofcom’s fundamental position should be that, in the context of these studies no undue constraints should be placed on existing services operating in accordance with the Radio Regulations.

Question 16: Do you agree with Ofcom supporting the extension of RDSS allocations in the band 2483.5 – 2500 MHz, whilst seeking to protect other services operating in the UK?

Intellect concurs with Ofcom’s approach in relation to this agenda item. Global Positioning System use is likely to be become more extensive and we agree that greater capacity to support the operation of these systems is necessary. We therefore support an extension of this existing Region 2 primary and Region 3 secondary RDSS allocation to a global primary allocation. Regulatory provisions should be harmonised if possible. However, as Ofcom points out, there are existing services in these ranges and our support would be conditional on relevant studies showing that potential for interference with them is minimised.

Question 17: Do you have any view on the introduction of radiolocation in the band 15.4 – 15.7 GHz?

Intellect would concur with the view that any introduction of radiolocation in these bands should be dependent the protection of the existing radio-navigation systems and of radio- astronomy already operating in it. Part of this band is also being considered under agenda item 1.25 for a possible MSS uplink allocation. Recognizing that there does not appear to be a strong interest in the UK in new radiolocation applications in this band, consideration should be given to allocating at least a part of this band to MSS uplinks.

Question 18: Do you have any comments on the use of spectrum above 275 GHz?

The current agenda item is principally concerned with passive services, and has largely focused on adding an ever growing list of spectral lines to the current 5.565 Footnote. Intellect

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recognises that some of the Passive Services do play a key role in monitoring our planet, and support the monitoring of the effects of climate change. However, it is important that the development of innovative active technologies and services is also fostered at these frequencies. At present, 5.565, even in its present form without further frequency additions, acts as deterrent to such developments. We believe that there are a number of exciting opportunities for active systems and services to use them. These include, specifically, active imaging systems used by medical, industrial and security scanners. There is also potential for use by wide bandwidth short range wireless links and/or personal area networks (IEEE 802.15) and high resolution short range safety radars.

In the course of considering the UK position for WRC12, we would urge Ofcom to promote the review of the current Footnote 5.565, with the aim of introducing far greater flexibility for innovation. We would also encourage future studies or Agenda Items in relation to these frequencies to be more even handed and to consider active applications. There is a significant opportunity cost in not doing so. Failure to revise 5.565 in this way at WRC12 would cause considerable uncertainty for years after for UK innovators, especially given the difficulty and timescales associated with setting and agreeing agenda items at future WRC’s.

Question 19: Do you have any views on space research use of the band 22.55 – 23.15 GHz? Is there a current or expected future demand from other services to use this band?

Intellect concurs with the Ofcom view on this agenda item, in that the UK has significant interests in space research through the European Space Agency. The planned establishment of a British National Space Centre, announced as part of the Space Innovation and Growth Team Report conducted by the Department for Business Innovation & Skills (BIS), appears to us to signify that these interests, and therefore the demand for spectrum, will only grow. Space Research services should be permitted to share this spectrum with incumbent users, provided that (as Ofcom note) any sharing conditions guarantee the required protection, and do not put undue constraints on those incumbent services.

Question 20: Do you support the protection of science services in the band 37 – 38 GHz? Do you know of any anticipated requirements for aeronautical mobile use or any other current or expected future demand in this band?

Intellect believes that space research services using this band should be protected as much as possible. We understand that sharing studies have indicated that use of this band should be restricted to land and maritime mobiles. Specifically, they have indicated that the masking requirements required for aeronautical applications not to interfere with Space Research Services using this band are high enough to severely restrict aeronautical use. This calls into question the ulitility of making such an allocation in the first place.

Question 21: Do you have any views on HF Oceanographic Radars operating in the range 3-50 MHz?

Intellect concurs with the Ofcom position on this item, and supports sharing studies between radiolocation services and incumbent services in the portions of 3-50 MHz that are identified as suitable for oceanographic radar applications.

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Question 22: Do you have any views on the protection of lightning detection systems from interference?

Intellect concurs with the Ofcom position on this item, and supports relevant sharing studies under the condition that no undue constraints are placed in existing services operating in accordance with the Radio Regulations.

Question 23: Should Amateur radio be given an allocation in part of the band 415 – 526.5 kHz, and if so where?

Intellect concurs with the Ofcom view that there is a need for balance of maritime, aeronautical and amateur interests in addressing this agenda item. That balance also requires that aeronautical and maritime usage of the band be efficient. In the course of assessing that balance, additional studies assessing how protection can be achieved need to be undertaken with particular reference to developments in other bands, such as those referred to under WRC12 Agenda Item 1.10

Question 24: Do you agree with Ofcom’s approach to support an allocation to the meteorological satellite service, subject to not constraining other services, in the band 7850 – 7900 MHz? Is there a current or expected future demand from other new services to use this band?

Intellect believes that Ofcom’s support of such an allocation has merit. We understand that compatibility assessments have showing that sharing of this band with Fixed Services under the same regulatory conditions as existing in the currently allocated band 7750-7850 MHz is feasible. These conditions are shown in Table 21-4 of Article 21 of the Radio Regulations, through the application of Table 8c of Appendix 7 for this band.

Question 25: What are your views on the need to introduce greater flexibility in the international regulatory framework and on Ofcom’s approach to agenda item 1.2?

Intellect supports an approach to this agenda item that develops concepts and procedures for enhancing the Radio Regulations to ensure that they will continue to respond to the current and emerging demands on radio services and technology evolution. However, Intellect asks that Ofcom ensure that the effect of any proposal on existing services be studied thoroughly before deciding to offer the UK’s support. This applies in particular to ongoing studies on the change to the definition of fixed and mobile service: a change that would be based on the network topology rather than physical mobility.

Convergence of technologies and services may call for a re-examination of some service definitions from time to time to ensure that artificial regulatory constraints on spectrum use are avoided where they are unnecessary. However, Ofcom must recall that many decades of research were required to develop the current definitions in the Radio Regulations. The business cases for networks of all kinds are predicated on the certainty that these definitions confer, and the access to spectrum they enable, safe from harmful interference. Any change to the use of a particular spectrum band requires thorough study and international co- ordination to ensure that all eventualities are considered. Intellect believes that this continues to be the best process for modifying the Radio Regulations and allowing for change while maintaining the certainty of service allocations and the transparency of international decision-making.

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The harmonisation5 of services and their allocations internationally plays an important role in the ability of consumers to take up new services and technologies. Ofcom should ensure that any flexibility introduced to the Radio Regulations does not hobble the role of the Radio Regulations in guiding policymaking internationally. Without this certainty, the economies of scale required to successfully launch products on a regional or global basis, are harder to realise.

Intellect therefore asks that Ofcom ensures that any steps it takes on this issue are in support of UK industry, and we ask that industry be allowed the opportunity to comment on Ofcom’s proposals before they are presented in international fora.

Question 26: Do you agree with Ofcom’s view that no changes are needed in the Radio Regulations to implement SDR/CRS?

Intellect agrees that there is no need to regulate Software Defined Radio (SDR) and cognitive radio systems (CRS) in the Radio regulations. We support all efforts to increase spectrum efficiency and believe that CRS is a useful and effective way of doing so, subject to the effective protection of other services that may be operating in adjacent bands. Also, as Ofcom note, there is a need to harmonise spectrum access for CRS, but this should be achieved outside the Radio Regulations on a non-mandatory and region by region basis by means of ITU-R Recommendations.

Question 27: Do you agree with Ofcom’s view that it is not necessary to regulate SRDs via the Radio Regulations?

We agree with Ofcom that there is no need to regulate use of SRDs via the Radio Regulations. Intellect has already encountered a range of issues in the UK that have delayed the deployment of SRD’s in the UK market, whereas in other markets (up until July 2008), they were freely available. There is no reason to delay or reduce the benefits that SRD use can bring to both UK citizens and those in other countries. Regulations of emissions by SRD’s can be achieved via the development of ITU-R Recommendations, taking into account Resolution ITU-R 54 if deemed necessary.

Question 28: Do you have any comments concerning the standing agenda items?

WRC12 provides an opportunity to address long-term strategic issues relating to current international orbital slot and frequency filing processes and procedures in the FSS sector. The current environment unintentionally creates market bottlenecks, prevents meaningful competition and removes incentives for market innovation, especially in relation to satellite platforms optimised for broadband and NGA services.

The current international orbital slot access and frequency coordination process is susceptible to the blocking of valuable FSS resources by satellites that never make it into orbit.

Intellect encourages Ofcom to influence where possible any opportunities for ITU initiatives to address the inefficiencies in the process of filing and processing satellite systems in order to achieve greater efficiency in the use of the scarce orbital and frequency resources. For example, modifying Resolution 49 to require a submission of information closer to the actual

5 By harmonisation at an ITU level Intellect means that, in terms of frequency allocations in Article 5 of the RR to the extent to which these are evolved / updated /maintained at ITU WRCs, This is not to be confused with spectrum harmonisation

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date of bringing into use of frequency assignments at a given orbit location would make it easier to confirm the accuracy of the information submitted. It would be in the UK’s interests to ensure that the satellite orbital and frequency resources are used efficiently. This would improve the possibilities for growth of services delivered by satellite in the UK and services delivered globally by satellite by UK companies.

Intellect members look forward to working closely with Ofcom to identify specific proposals on improvements to the ITU coordination and notification procedures for satellite networks.

Question 29: Are there any items you wish to see addressed by future WRCs?

One of the most crucial items yet the least transparent/accountable is the process for setting future WRC agenda items. At any given conference the agenda for the next and outline for the following one is set. So for example WRC-12 will set the agenda for WRC-16 and a provisional agenda for WRC-20.

Intellect is also disappointed that Ofcom has not itself been forthcoming with information regarding its own priorities for the future. In many respects this lack of transparency lead us to a repeat of the problems that our response to Question-2 refers to.

As it stands, Resolution-806 (the WRC-15 Provisional Agenda) calls for further consideration of spectrum for unmanned aerial systems and 5.1GHz FSS spectrum. Other potential topics of interest to Intellect members (or likely to be timely for consideration) are studies related to further digitization of broadcasting (e.g. VHF Band II), spectrum demands from advanced mobile/broadband/satellite services (baseband and backhaul) and formal allocations above 275GHz.

Whilst individual Intellect members may be able to advise directly of more specific interests, what is important is that Ofcom must improve both the national preparatory process and its ability (in conjunction with CEPT) to more successfully influence conference on such a key item.

-END OF INTELLECT RESPONSE-

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Annex One

Airwave Solutions Ltd Analysys Mason Limited Arpeggio Ltd. Astra (GB) Limited Astrium Limited Avanti Communications Limited BAE Systems Bird & Bird Bluenowhere Ltd BT Group Plc Cable & Wireless UK Capgemini UK Plc Dell Corporation Ltd Deloitte EADS UK EDS, an HP Company Ericsson Limited Eutelsat Fujitsu Telecommunications Gemserv Ltd General Dynamics UK Limited Hardcat Limited Huawei Technologies (UK) Co Ltd Hughes Network Systems Ltd IBM United Kingdom Limited Global Limited Intel Corporation (UK) Ltd Logica Microsoft Ltd. Motorola Ltd Mott MacDonald Limited Nokia (UK) Ltd Nortel Networks UK Limited Olswang Plextek Ltd QinetiQ Group QUALCOMM Roke Manor Research Research in Motion UK Limited Samsung Electronics UK Ltd Sapient Ltd Savant SELEX Communications Limited SELEX GALILEO Sony United Kingdom Ltd Thales Plc UK Broadband Ltd VEGA VT Communications Limited

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