Wireless Broadband Alliance.Docx
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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 Wireless 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 Internet of Things, Big Data, Converged Services, Smart Cities, 5G, etc. Today, membership includes major fixed operators such as BT, Comcast and Time Warner Cable; seven of the top 10 mobile operator groups (by revenue), AT&T, China Mobile, China Telecom, China Unicom, Deutsche Telekom, 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, Cisco Systems, Comcast, Intel, KT Corporation, Liberty Global, 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 bandwidth to make sufficient return on their implementation investments. Bandwidth at this range is not large enough for traditional operators to make the appropriate infrastructure 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 Telecommunications 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,