Title:

Mr

Forename:

Bruno

Surname:

Tomas

Representing:

Organisation

Organisation (if applicable):

Wireless Broadband Alliance

What additional details do you want to keep confidential?:

No

If you want part of your response kept confidential, which parts?:

Ofcom may publish a response summary:

Yes

I confirm that I have read the declaration:

Yes

Additional comments:

WBA Background -

Founded in 2003, the mission of the Broadband Alliance (WBA) is to champion the development of the converged wireless broadband ecosystem through seamless, secure and interoperable wireless broadband services for delivering outstanding user experience. Building on our heritage of Next Generation Hotspot (NGH) and carrier Wi-Fi, WBA will continue to drive and support the adoption of Next Gen Wi-Fi and other license exempt wireless services across the entire public Wi-Fi ecosystem, including of Things, Big Data, Converged Services, Smart Cities, , etc. Today, membership includes major fixed operators such as BT, and Time Warner Cable; seven of the top 10 mobile operator groups (by revenue), AT&T, , , , , Orange and Telefónica, who primarily utilize licensed spectrum but also have interests in license exempt spectrum, and leading technology companies such as Cisco, Microsoft, Huawei Technologies, Google and Intel. WBA member operators collectively serve more than 2 billion subscribers and operate more than 25 million hotspots globally. The WBA Board includes AT&T, Boingo Wireless, BT, China Telecom, , Comcast, Intel, KT Corporation, , NTT DOCOMO, Orange and Ruckus Wireless. For a complete list of current WBA members, please http://www.wballiance.site/join-us/current-members/.

Shared Spectrum Context -

There is a growing trend by policymakers and regulators moving to introduce new models for spectrum management that would provide coordinated use of shared spectrum. A key objective of these programs is to provide conditional access to portions of spectrum with varying levels of priority based upon status (e.g. incumbents, priority users, general users). Due to this dynamic and flexible approach to spectrum access, these new frameworks do not align neatly with existing standards bodies and industry organizations, which are primarily focused on either fully licensed or license exempt spectrum and technologies.

Thus, WBA is championing a Coordinated Shared Spectrum work group which is currently the most well positioned effort in the industry to do early stage analyses of these spectrum sharing initiatives because the WBA is an organization with membership spanning both the licensed and license exempt environments. As a result, this work group is evaluating both the business models that will be supported by Coordinated Shared Spectrum management regimes and subsequent pre-commercial trials.

Specifically relating to this response to Ofcom, this group has hosted 6 meetings during April-May to discuss and draft a well-balanced response, across both the vendor and operator communities. WBA believes maintaining a line of communication with Ofcom might help drive the ecosystem forward, leveraging as well on its regional members based in the UK.

Moreover, WBA has a strong heritage of championing services and interoperability on license exempt spectrum band technologies, such as the definition of the first Wi-Fi roaming standards and cellular-like mechanisms defining the Carrier Wi-Fi industry term. As a result, this know-how and track record will be effectively transposed to other frequency bands currently being considered.

Question 1:Given the nature of the incumbents and their use of the spectrum, what new types of applications do you foresee could access this spectrum on a shared basis? Please provide details on the potential applications and their characteristics of use as identified in the spectrum sharing framework.:

While we generally would advocate for technology-neutral and service-neutral approaches to spectrum allocations, if a sharing framework is to be considered, we recommend that that it is flexible enough to accommodate a range of technologies and potential applications. Given the early stage nature of the consultation, we understand the value in analyzing the most likely near-term uses of the spectrum and assessing its suitability for sharing.

It is worth noting that it is not possible to forecast the longevity of current applications in a particular band, neither is it possible to predict future applications the market may demand. It is therefore, important to consider flexible, general-purpose spectrum allocations to limit unnecessary restrictions in novel applications within the band.

However, based upon the amount of spectrum that may potentially be available for shared access use across much of the geographic area of the UK, as well as the frequency range of 3.8 to 4.2 GHz, we could envision the following types of service offerings being deployed on a shared access basis.

- Mobile Broadband (both LTE and future 5G) o Indoor and outdoor. o Given the propagation characteristics at these frequencies, we would anticipate mobile broadband deployments in the form of small cells, but this should not be a regulatory mandate.

- Wireless Backhaul o Outdoor backhaul services of Mobile Broadband Access. o The majority of use cases would be for fixed locations, but there are a few applications for mobile backhaul.

It is important to emphasize that at this early stage in the development of the band, there should be a strong regulatory focus on the technical rules (i.e. coexistence studies, power limits, out-of-band emissions, etc.) governing the band. These technical rules should then inform the kinds of applications to be utilized within the band.

Overall, the possibility of broad participation and wide range of potential applications for this band could offer significant benefits to the citizen-consumer as well as providing clear opportunities for enhanced spectrum efficiency.

Question 2:Based on information provided in this Section, can you identify any barriers to enhanced sharing in the 3.8 GHz to 4.2 GHz band? Please use the Spectrum Sharing Framework, which identifies four types of barriers to spectrum sharing: lack of information, market barriers, technology barriers, and authorisation barriers.:

Market Barriers

In section 2.32 of the consultation document, the text states that "there is no EU harmonization legislation governing the 3.8 GHz to 4.2 GHz band." Ofcom also states that "although this band may be of future interest for mass-market mobile services, for the foreseeable future its prospects for international harmonization appear to be low."

As we look towards 5G, the C-band is one of the bands targeted towards delivering on enhanced mobile broadband communications - and many markets are exploring this range for 5G applications. While it may be true that there is no EU harmonization legislation governing this band right now; many large, first mover markets, like North America, Europe, China, Japan and Korea are exploring portions of the C-Band for future 5G deployments. However, it is unclear whether or how a sharing framework would be applied in those explorations.

Additionally, in section 2.17, Ofcom states, "Ranges are based on the Fixed Link's channeling arrangements, in which there are nine 2 X 30 MHz duplex channels." Operators need sufficient to make sufficient return on their implementation investments. Bandwidth at this range is not large enough for traditional operators to make the appropriate investments without exploring carrier aggregation models. In addition to the bandwidth limitation operators also need full control on the assigned spectrum which they can use to implement efficient RRM procedures. This limitation could stifle growth for non- traditional service providers, such as enterprise or venues.

It is also worth noting that pending legislation in the US Congress (the Mobile Now Act) would charge the Federal Communications Commission (FCC) and National and Information Administration (NTIA) with conducting a feasibility analysis of spectrum sharing in the 3.7 GHz to 4.2 GHz band. The emergence of a spectrum sharing framework in this band in the US would be very complementary to an Ofcom framework in 3.8 GHz to 4.2 GHz.

Authorization Barriers:

As the consultation document is in an early stage, clarity is required to fully examine the authorization barriers. As it relates to the tiered model, the text introduces concepts that raise many questions, which underscores the uncertainty around how incumbents, geographic licenses and/or opportunistic access might coexist in the band. This market uncertainty, reduces incentive to invest in the band and will be a significant barrier to entry.

Tier 1 - Current Incumbents: In section 3.10, the text states, "However, our preliminary view is that if we proceed with a multi-tiered authorization approach then we should also continue to allow Tier 1 licensees to grow their businesses in this band, and on the continued basis of first-come-first-served coordination mechanisms that these licenses are currently subject to. This of course may indirectly limit the amount of spectrum available to them, depending on the popularity of geographic licenses that have been issued." This statement introduces significant uncertainty around unpredictable expansion of incumbent usage in the band. If incumbents increase their businesses without any restrictions, there will be very limited opportunities for other Tiers to implement and deploy commercially viable products as this will adversely impact the quality of service they wish to provide. One would presume this band was selected as a sharing candidate band by Ofcom because incumbents have not shown historic expansion trends. That history should be used to place quantifiable limits on incumbent expansion so that future participants in shared tiers have the ability to forecast the future opportunity and risks.

Tier 2 - Geographic Licenses: According to the text, there will be a fixed frequency allocation per geographic area. This raises the question - in this approach, how will Tier 2 differ from Tier 1? The text also mentions that there may be a flexible allocation on the amount of spectrum per geographic area, but this implies time-based usage variations. This should be better quantified in order to assess the market opportunities and risks. In this scenario, what is the statutory duty to optimize the use of the spectrum, and over what time frame? What is the granularity of geographic licenses? What is the duration for these licenses? These questions need clarity for effective deployment.

Tier 3 - Opportunistic Access: The consultation mentions two approaches for managing opportunistic access 1) rules based access (i.e. centralized coordination), which is based on availability and subject to preemption by higher tiers and 2) uncoordinated license exempt access. This raises the following questions: 1) Should there be a minimum amount of spectrum for each geographic area guaranteed for Opportunistic Access? Given geographic and frequency fragmentation of incumbent usage, is fully license exempt use practical? How would co-channel coexistence be addressed?

Technology Barrier: All of the above uncertainty, contributes to difficulties around appropriate market sizing and technology development. Because of the ambiguity of the current regulatory framework, we will also see challenges with interoperability which will directly affect the ability for equipment manufacturers and infrastructure network providers to reach scale as it relates to the device and radio access networks.

It is recommended for Ofcom to consider providing a clear, simple regulatory framework that reduces uncertainty for 3.8 GHz to 4.2 GHz investment - this will reduce barriers and allow rapid deployments in the band.

Question 3:Do you agree with our initial assessment of a potential application of a tiered authorisation approach in this band?

If yes, please provide as much detailed information as possible of how you consider any tiered authorisation approach may enable greater spectrum sharing and how it could be implemented in practice.

If no, please describe the spectrum access method that you consider may best meet any requirements you have to access spectrum in the 3.8 GHz to 4.2 GHz band.

Please give specific details of how you would envisage this working in practice, where appropriate with reference to the tools and enablers identified in the Spectrum Sharing Framework. :

Given the target band has incumbents with sparse geographic deployments, the application of a tiered authorization approach for spectrum sharing in this band is feasible. It should be noted, however, that the diversity of tiered approaches with different ways of geographic and/or time sharing, combined with the very early stage nature of tiered sharing models - it is difficult to recommend one particular approach. We believe that other examples and proposals for tiered sharing of spectrum, including Licensed Shared Access (LSA) and the Citizens Broadband Radio Service (CBRS) could serve as points of reference for spectrum sharing frameworks. We note however, the CBRS is being applied to a spectrum band with significant incumbent exclusion zones covering approximately 40% of the US population, the band under consideration here has different characteristics, so the sharing framework considerations would be different.

Both 2 Tier and 3 Tier models have been proposed to attempt to gain more efficient utilization of spectrum resources.

Specific comments and questions regarding a tiered authorization approach include:

General - While protection of incumbent and higher-tier users must be the highest goal of a shared spectrum framework, in order for adoption to occur and an ecosystem to flourish it is also necessary to ensure that each tier of the framework has access to some portion of the shared resource. In defining the rules and terms of shared spectrum access, the regulator must strike the right balance between flexible assignment of spectrum and some level of availability at each tier. - While there is certainly cost and complexity associated with a database-coordinated access model, the benefits of such an approach may justify the investment, and could be explored.

Geographic Licenses - One of the most critical aspects of geographic licensing would be the area to be covered by such licenses, this will need further clarification. - Duration of these licenses will also be key. In order for prospective licensees to participate in acquiring licenses they must have a reasonable expectation of recouping their investment during the life of the license. In future stages of the consultation process, approaches that create certainty should be considered. Some of these may include: o Guarantees on renewability of licenses, perhaps with a limit on the number of times a license is guaranteed to be renewable by the current holder. o Shorter license durations could result in lower prices, opening up the geographic tier to non-traditional entrants and providing room for service innovation at a lower cost of entry. - A flexible / frequency agile approach to spectrum allocations for geographic licenses could be considered. Coordinated access can be used to guarantee the geographic licensee that in the event of incumbent preemption their service can be reassigned to another portion of the band. - The details of the framework and license assignment can be structured in such a way as to ensure geographic licensees do not preclude access by other stakeholders to the spectrum.

Opportunistic Spectrum Access - Enabling opportunistic access will invite greater participation and could promote innovation in the band. - Because the costs to utilize spectrum opportunistically are typically minimal, the resulting benefits can be passed on to the citizen-consumers. - While technically not opportunistic spectrum access, uncoordinated license exempt access is possible. However, it would require that devices (both infrastructure and end user equipment) know the specific frequency range(s) that are available for such operation i.e. static allocation. - In contrast, database coordination for opportunistic access is consistent with the overall efficiencies gains resulting from a dynamic sharing framework.

Question 4:Should a potential future tiered authorisation approach to spectrum access in the 3.8 GHz to 4.2 GHz band accommodate changes from incumbent services of the spectrum? I.e. should new licences or variations to existing fixed link and satellite earth station licences be allowed to continue on a first-come-first-served co-ordinated basis?:

As has been noted in our previous responses, we believe that uncertainty or variability regarding incumbent tier usage will negatively impact adoption and investment at the shared tier(s). If possible, it would be most desirable to accommodate future expansion or adjustment of incumbent operator usage within the the structure of a new spectrum sharing framework. If it proves necessary to provide for some expansion or adjustment of incumbent usage within the first-come-first-served basis that has been the existing allocation paradigm for the band, we would recommend that some limit be placed on the amount of addition spectrum that may be allocated under this model (e.g. No more than 10% of the amount of spectrum currently allocated for incumbent users within a defined geographic area [the sub areas used for Geographic licensing] may be assigned under Ofcom's first-come-first-served- basis). Additionally, the specific requirements and parameters under which this limited spectrum would be assigned within the traditional model should be clearly published to all participants.

For more information please contact the WBA PMO ([email protected]).