Ofcom BRIG meeting: The need for evidence
Written by: Sam Fenwick | Published:

The UHF strategic review, the possible release of Home Office spectrum and the future introduction of LTE into the 450-470 MHz band were touched on at the Ofcom Business Radio Interest Group (BRIG) meeting. Land Mobile reports.

The pace of construction in London has led to congestion and is a challenge for network planner; Credit: iStock/melaniekjones

Kevin Delaney, spectrum policy and planning manager at Ofcom, kicked off his part of the discussion by commenting on Ofcom’s thinking on the UHF Strategic Review. “We’re are very cautious on this. We’ve seen the numbers for the amount of stakeholders in this area and the thought that if we go down a particular route we might be inconveniencing [them] attracts a certain amount of nervousness,” he says. “I think what unnerves us is the lack of hard evidence. We can say how many assignments we have in UHF1 or UHF2 but market demand, future trends and technologies appear to be where we are tripping up slightly.

“Ofcom is questioning why a particular industry or a particular segment has to be in UHF. Is it because they’ve always been there or is it that’s all the manufacturers produce? They might produce [the equipment] on a European or global scale in that frequency range.”

“Ofcom should not leave this room with the view that if we can’t come forward with a case [for business radio use of UHF] that is virtually identical to us not needing the spectrum,” says Tim Cull, head of business radio at FCS. “We do need the spectrum. We can’t come forward with a coherent case easily because of the difficulty of putting it together, nothing more than that. We still need spectrum.”

He explains that the difficulty of making a coherent case is compounded by the large number of Business Radio stakeholders and makes comparisons to mobile operators: “It’s very difficult getting two MNOs saying the same thing in the same room. They have difficulties and there’s only a handful of them.”

Keith Smale, branch director at 2CL Communications, makes the case for “blocks that are reserved for certain users on the grounds of safety and public interest”, adding that if Ofcom took the “drastic step” of a full realignment in the UHF band it would give it the ability to take fragmented spectrum and allocate it to commercial users and then build these reserved blocks from the rest of the available spectrum.

He draws attention to the “confusion” caused by the removal of the NHS central licence. “It’s nothing but a paper exercise between two government departments, wasting a gross amount of money and a hell of a lot of time for the NHS facilities managers. They should have their own block of frequencies and Ofcom and the NHS should come to an arrangement for a fee.” He explains that the current situation generates a lot of work for Ofcom’s enforcement managers due to a lack of education on the issues surrounding radio licences among NHS facility managers.

Smale describes a particularly bad example: “A few years ago I went into a large hospital in South London and Ofcom was sending reminders to a portering manager who had died 18 years previously because we hadn’t been kept up-to-date.”

Speaking on the UHF review, he says: “Now is the time, it’s almost like a seesaw [moving towards digital]. What you don’t want is large- scale users saying ‘sod it, I’m going to stick with analogue and buy in new analogue kit’, that’s where you’re going to start getting serious compensation claims [in the event of changes to UHF].”

Smale highlights the extent of the spectrum congestion in the London area. “There’s a massive building [that] we could not get any spectrum for so it’s got an IP solution, which is not exactly what the client wanted but it’s doing the job. If we were to follow a path like that... I think you could get truly efficient spectrum use. Being made to get rid of their obsolescent equipment is going to hurt a few businesses, but it would do the whole industry and the regulator a massive favour.”

Land Mobile asks whether something like a spectrum access system (SAS) [see our article on in-building propagation here – Ed], could be a solution to congestion. It would be more spectrally efficient to have a system that serves a large number of radio-using organisations using a common pool of spectrum by assigning a channel on a temporary basis for each call. However, attendees point out the fact that “everything’s pre-tuned” along with the desire among companies to own their own network. Concerns were also raised as to how such a system would work in remote areas with poor connectivity or for equipment that travels around a lot.

Smale states the need for Ofcom to do a census to get the best possible idea of the extent to which radio is used, adding that he has encountered large companies that are only using two out of five of their frequencies.

“The fact that all the channels are allocated and paid for doesn’t give the full story. There are thousands of channels out there used once every so often,” says Steve Cairns, MD of wide area network operator R F Lincs. “I’ve said for a long time we need to be looking at that. The fact they’re all being bought and paid for is not the point, the usage is key.”

Home Office spectrum release
Delaney emphasises that the spectrum that may be released by the Home Office as a result of the move to the Emergency Services Network (ESN) is not contiguous. He went on to say that if it happens there would be an immediate benefit for PMR and PMSE and that the proposed shift to higher Quality of Service (QoS) values (see below) combined with this release could make it easier to make assignments in London and allow

Ofcom to bring back data-dominant channels. Kuha Sithamparanathan, spectrum policy manager, emergency services at Ofcom and FM PT 54 on Private/Professional Land Mobile Systems (FM54) chairman, notes that the prison service has recently moved to a TETRA system and that currently the emergency services hold about 7 MHz of spectrum in UHF2, of which they currently share 4 MHz with other users under a reserve model. He adds that there is potential to use the white spaces between prisons. Sithamparanathan says that the amount of spectrum that could be released could easily be 5 MHz and that he expects Ofcom will review the situation with the Home Office in February 2017 to understand what it can release on a more permanent basis. As the ESN is meant to go live mid-2017 he expects the Home Office to be able to make a decision “towards the end of 2017 or so”.

Derek Banner, chairman of the Critical Messaging Association Europe, suggests that it could be worth looking to move the prison service to different frequencies to make the Home Office spectrum more contiguous, arguing that “they probably don’t have too much use or equipment, things like that can be moved. If you can pick up 4 MHz and make it more contiguous for a relatively small expense it might be worth looking into.”

“What we don’t want is a piecemeal filling up of the space, says Sithamparanathan. “We’d like to be able to create proper allocations that can support the congestion issue in the South East as well as potentially cater for new technologies.”

FM54 – LTE in UHF
Sithamparanathan gives a summary of the FM54 meeting held in Copenhagen last December. The group agreed on a proposal to Working Group Frequency Management (WGFM) to request compatibility and sharing studies in WGSE (Working Group Spectrum Engineering) for the use of LTE in the 450- 470 MHz band. He says that FM54 has asked WGSE to try to complete this work for next year.

Sithamparanathan explains that part of the rationale behind this decision is that some Nordic countries are looking to change from CDMA to LTE. One of FM54’s tasks is to produce an Electronic Communications Committee (ECC) report that will give administrations guidance on how to better share frequencies for greater efficiency. He notes that a lot of European countries are looking to the UK in this area as in mainland Europe there’s very little sharing, and the UK (as one of the biggest PMR markets in Europe) saw a bit of a reinvention with the business radio reform. “Keep in mind that it’s not a case of trying to usurp the existing PMR use in the band to LTE,” he adds.

Cull asks what will happen when an administration makes an assignment for LTE within the 450-470 MHz band: “Will the guard bands lie within the assignment or will they be placed outside the assignment as happened for L-band?”

Sithamparanathan replies by saying that it is a ”little premature” to ask such questions. He says that he believes “even a 3 MHz type of system could be accommodated in the band “right now”.

Cull expresses concern that it could turn into a harmonisation measure to force PMR out of the band. He says that Ofcom “is onside” with business radio but “I don’t think that’s true elsewhere”. He also noted that there might be a competition issue, in that the size of the band lends itself to only one MNO operating within it.

FM54 will ask WGFM to decide whether the 410-430 MHz range should be studied for broadband PMR/PAMR as five European Conference of Postal and Telecommunications Administrations (CEPT) have indicated an interest in such research.

Legislation matters
Delaney brings up some proposals relating to the technical assignment criteria, such as that to reduce the wanted threshold to -92dBm, a reduction of 12 dB for Band One and Low Band. Another proposal is to increase the QoS maximum value to three from two, with a view to increasing it further to four depending on how the first increase is received by the market. A Transfinite report highlighted the possibility of taking the QoS value up to four or six for voice only channels.

Ofcom’s plan is to consult on these proposals in February/March 2016, and according to Cull the FCS agrees that “this is probably a very sensible course of action”. He notes that “with a little bit of stirring around” this could lead to the creation of data-only channels.

“I think the rise and rise of data is a big opportunity that the industry is nicely positioned to take great advantage of,” Cull says. “We’re going to make a fortune provided we get it right.” He adds that data applications can “change the RF performance of devices in a way that would affect the Wireless Telegraphy Act” so users have to “be very careful of that”.

Delaney draws attention to the new planning criteria for in-building installations for tall structures (>30 metres). Radiating cable gives the regulator the best chance of making an assignment. “If the application proposes use of an antenna that is not a radiating cable or distributed antenna system then you will be asked to provide the engineering justification of the proposed choice” states the guidance.

For radiative cable, the regulator now assumes 50dB coupling power loss, requires that handheld receivers should use antennas with 10 dB loss, and the handheld transmit power should be limited to a maximum of 250mW (24dBm). The terminals are likely to be the limiting factor as to whether Ofcom can make an assignment. In addition, the maximum power for the highest terminated cable should not exceed 100mW (20dBm). For distributed antenna systems the maximum RF level from each antenna above ground must be no more than 10mW, or 100mW below ground. Delaney welcomes feedback on this guidance.

Commenting on the new market access regulation that comes into force this year, Cull says: “[It] places the FCS in the most invidious position because we cannot in any conscience indicate to members that they should not obey the new law. At the same time we cannot in any conscience tell our members to obey the new law and suffer an increased commercial disadvantage. We must have enforcement to level the playing field, so that people who do not do things right get nailed because those who do comply will suffer a cost disadvantage. “Small companies who are going to supply just the UK market with products have £100,000 in compliance costs by the time it’s all added up,” he continues. “The UK market might not be so exciting if you have £100,000 deducted straight from your bottom line – it turns it into a nightmare. Which is why Kuha [Sithamparanathan] and the boys had better not get the UK stuck on its own, because if that’s the case PMR in the 450-470 MHz band might be a UK-only deal and the volumes are so low we’re dead.”

He also mentions that site inspections are likely to increase. The FCS understands from comments made at various BRIG meetings that “the standard of some radio installations is so appalling it doesn’t even meet basic safety standards, never mind that it works properly as a radio.” He adds that the FCS is planning to provide advice to purchasers of radio systems to try and improve the standard of installations. “If the thing looks like a mess the chances are it is a mess,” he offers.

On a more explosive note, one attendee highlights issues with the supply of ATEX equipment, particularly ignorance of its importance. He explains: “The amount of time we specify what we want, we give the ATEX numbers and we still get sent the wrong equipment...”

Smale chimes in, saying “I’ve had requests from shipping agents [for equipment]. So now we Google the ship and check what it is. Some years ago someone was trying to put standard equipment on a bulk gas carrier so I phoned the guy and said ‘you’ve got to be joking!’”

Delaney touches on the situation regarding the use of the Mid Band (136-165 MHz) in the South of the country. Following an update from France, Ofcom licensees will be able to operate in these bands but will have no right of complaint if they suffer interference from French military transmissions.

Ofcom has drafted a legal disclaimer for such licences, which has been sent to its legal team for review. It is interested to hear the business radio community’s views on the extent of the risk of interference and whether they will accept the risk in return for access to this spectrum.

Judging from the passionate discussion, there’s little doubt that business radio is at a turning point. It will be interesting to see how Ofcom and the business radio community tackle the problems of congestion in the London area, and whether opportunities (such as the “rise and rise of data) and threats (such as the introduction of LTE into the 450-470 MHz band) can be addressed to everyone’s benefit.

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