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Use of the 1781.7-1785.0 / 1876.7-1880.0 MHz Bands

for the Provision of GSM 1800 Telecommunications

Services

A Consultation Document

April 2003

The Radiocommunications Agency is an Executive Agency of the Department of Trade and Industry.

The Agency's website is located at www.radio.gov.uk

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EXECUTIVE SUMMARY

1.1 This consultation document reviews possible options for the use of all or part of the 1781.7-1785.0 MHz band paired with the 1876.7-1880.0 MHz band to provide telecommunications services based on GSM 18001 technology.

1.2 The 3.3 MHz band at 1876.7-1880.0 MHz currently serves as a guard band to protect GSM 1800 services against interference from DECT2 systems and vice versa. However, based on the conclusions of ERC3 Report 100 (“Evaluation of DECT/GSM 1800 compatibility”)4 and RA’s5 own analysis, a 3.3 MHz guard band between GSM 1800 and DECT is no longer considered necessary. The 1781.7-1785.0 MHz paired band is currently unassigned. A band plan is shown in Appendix A, and further technical considerations are given in Appendix B.

1.3 The bands under consideration form part of the overall GSM 1800 spectrum, 1710-1785 MHz paired with 1805-1880 MHz. This spectrum is identified in ERC Decision (95)036 for the provision of mobile telephony services based on GSM technology.

1.4 As GSM 1800 is harmonised (within Europe), handset manufactures produce phones that operate over the entire GSM 1800 spectrum. The Government has licensed the entire available spectrum identified for GSM (both the GSM 900 and GSM 1800 bands), excluding guard bands where these have been thought necessary. The final awards were made following the consultation “Mobile Phone Spectrum over the next decade”7. Consequently there is an enormous existing market for GSM 1800 phones, together with low equipment costs and innovative products.

1.5 RA has received a number of requests from industry expressing interest in using this spectrum to provide telecommunications services, ranging from short-range in-building solutions to GSM services on commercial airliners and passenger ferries.

1.6 Three basic scenarios for the use of this spectrum have been identified, and views on each are sought. These scenarios are as follows:

to make the spectrum available, on a national or regional basis, to either the existing GSM operators or to new entrants for the provision of public mobile telecommunication services;

to make the spectrum available for short-range, low-power use on a licence-exempt basis; or

to retain the guard band and leave the paired band unassigned, in order to assist migration of GSM 1800 to future IMT-2000 use and to facilitate Testing and Development licensing.

A related issue is whether to make the spectrum available in a technology-neutral way or to restrict it to GSM technology. For the second scenario, another related issue is

1 GSM: Global Systems for Mobile Telecommunications. 2 Digitally Enhanced Cordless Telecommunications.3 European Radiocommunications Committee.4 ERC Report 100, “Compatibility between certain radiocommunications systems operating in adjacent

bands. Evaluation of DECT/GSM 1800 compatibility”, Naples, February 2000.5 Radiocommunications Agency.6 ERC/DEC/(95)03, “ERC Decision of 1 December 1995 on frequency bands to be designated for the

introduction of DCS 1800”.7 Published by the Department of Trade and Industry, February 1996.

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whether to allow third-party public services or to restrict the spectrum to self-provided use.

1.7 RA would be grateful for written comments on the above scenarios, and in particular answers to the specific questions raised in Section 5 of this consultation document.

1.8 RA is required to complete and publish a Regulatory Impact Assessment (RIA) before any changes are made to the use of this spectrum. A draft RIA is attached to this consultation document, and will be developed in the light of responses to the consultation. Comments on the draft RIA are therefore particularly welcome.

2 RESPONSES TO THIS CONSULTATION

2.1 Responses to this consultation should arrive no later than 25 July 2003. These should be sent to:

Martin FentonPublic Wireless Networks UnitRadiocommunications Agency11R/2AWyndham House189 Marsh WallLondonE14 9SX

or electronically to [email protected] or by fax to 020 7211 0117.

2.2 This consultation document is also being published on the RA website, www.radio.gov.uk.

2.3 Any comments or complaints about the conduct of this consultation should be addressed to:

Julia FraserInformation and Publicity ManagerRadiocommuncations Agency9Y/14BWyndham House189 Marsh WallLondon E14 9SX

or electronically to [email protected].

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3 PUBLICATION OF RESPONSES

3.1 Respondents to this consultation should note that, in the interests of open government:

unless confidentiality is expressly requested, individual responses will be placed in the public domain in printed or electronic form, together with the names and contact details of authors. Respondents are requested to make it very clear if they wish to keep some or all of their response confidential;

unconditional permission to publish responses will be assumed unless the author expressly states otherwise;

any copyright attached to responses will be assumed to have been relinquished unless it is expressly reserved; and

where applicable, any information provided will be covered by the Data Protection Act 1998.

4 BACKGROUND

Current regulatory situation

4.1 The GSM 1800 spectrum, with the exception of the 2 x 3.3 MHz that is the subject of this consultation, is licensed on an exclusive national basis to the four current GSM operators: mmO2, Orange, T-Mobile and Vodafone. Between them they have 2 x 71.6 MHz of spectrum. See Appendix A for details of the current GSM 1800 and DECT assignments.

4.2 Within Europe, ERC Decision (95)03 designated the frequency bands 1710-1785 MHz and 1805-1880 MHz to DCS 1800 (GSM 1800) from 1 December 1995. Licensing of the GSM 1800 spectrum in the UK took account of the recommendations of ERC Report 318, which indicated that the minimum frequency separation required between GSM 1800 and DECT carriers is 5 MHz; hence the implementation of a 3.3 MHz guard band. See Appendix B for further technical details.

Future regulatory situation

4.3 It should be noted that the band 1710-1880 MHz (which includes the entire GSM 1800 spectrum) was identified by WRC-20009 as potential expansion spectrum for 3G/IMT-2000. As indicated in the UK Spectrum Strategy 200210, the Government expects that the GSM 1800 spectrum will be refarmed for 3G use in the longer term. However, the timing of this refarming will depend on the speed of growth in, and the nature of, 3G services, and on the demands that this will place on the spectrum, bearing in mind that additional 3G spectrum at 2500-2690 MHz is expected to become available from 2008.

8 ERC Report 31, “Compatibility between DECT and DCS 1800”, Brussels, June 1994.9 World Radiocommunication Conference 2000 (Istanbul, Turkey, 8 May to 2 June).10 “Strategy for the future use of the radio spectrum in the UK”, RA, April 2002

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5 PROPOSALS FOR USE OF THE SPECTRUM

5.1 Wide-area public use

5.1.1 At present there is a continuing strong demand for GSM services. Making additional GSM spectrum available to the existing operators could be very beneficial. Once existing channels have been exhausted, providing capacity in areas of high demand requires solutions such as cell-splitting or the introduction of micro and pico cells overlaying the macro-cellular network. These types of solution are expensive, as significant extra infrastructure is required (base stations, cell sites, backhaul, etc). Providing extra channels to the operators would increase the capacity of the existing network, thus reducing the need for extra cells in the future.

5.1.2 With approximately 2 x 3 MHz of spectrum, it would just be possible to implement a stand-alone wide-area macro-cellular network. This network would be limited in terms of the capacity it could provide, with little or no flexibility to cater for dense use in areas of high demand. Nevertheless, such a network might be attractive to certain operators, depending on the services envisaged.

Question 1 Given the other potential uses outlined in this document, do you consider it most appropriate to make the spectrum available for wide-area public use?

Question 2 If your answer to question 1 is yes, do you consider it most appropriate for the spectrum to be used to supplement the spectrum of the existing GSM operators, or to be made available for potential new GSM operators on a regional or national basis?

5.1.3 The report of the Independent Review of Radio Spectrum Management, published by Professor Martin Cave on 6 March 2002, recommended that:

“Recommendation 7.6 – Auctions should become the default means of assigning spectrum licences between competing users, to achieve an efficient market-driven outcome.”

5.1.4 In its response to the independent review the Government stated:

“Auctions remain our preferred method of assigning new spectrum but are not appropriate in all circumstances.”

5.1.5 For the above reasons, if it were decided to make the spectrum available for wide-area public use, the favoured mechanism would be via an auction.

Question 3 If your answers to questions 1 and 2 are yes, do you consider it most appropriate for the spectrum to be awarded via an auction process?

5.2 Short-range, low-power GSM use on a licence-exempt basis

5.2.1 As an alternative to wide-area public use, the spectrum could be given over to short-range, low-power use on a licence-exempt basis – either for self-provided, private use or for public services provided by third parties for closed-group working. It is anticipated that the technology would remain based on GSM standards.

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5.2.2 A number of potential applications for this kind of use can be envisaged, including:

wireless office;

retail (supermarkets, shopping centres); and

museums and galleries.

5.2.3 One significant advantage of this type of low-power, licence-exempt GSM use is that operators/service providers might be able to make use of the existing base of GSM handsets, thus significantly reducing entry costs. (Recent estimates put the number of current GSM subscribers in the UK at around 50 million11.) As an example, one could envisage a wireless office solution where users could be connected to the normal land PSTN network using their GSM mobiles, via an office-based GSM pico cell connected to the company PBX. When they leave the office, users would then roam onto their normal public wide-area GSM providers’ networks.

5.2.4 Another use could be within museums/exhibitions, providing information about exhibits to visitors as they wandered around. Alternatively, in the retail environment, supermarkets could text customers with details of special offers and other promotions as they moved through the store.

Question 4 Given the other potential uses outlined in this document, do you consider it most appropriate to make the spectrum available for short-range, low-power GSM use on a licence-exempt basis?

Question 5 If your answer to question 4 is yes, what kinds of application do you anticipate will develop? Estimates of potential market size and anticipated penetration would also be useful.

5.2.5 Another low-power, licence-exempt use that could be envisaged is the provision of public GSM services to passengers on ferries and aircraft, where either they are outside their land network’s normal coverage area or normal GSM operation is prohibited for safety reasons (as on airliners). However, a number of significant regulatory difficulties (which are outside the scope of this consultation) would need to be overcome before use on passenger ferries and aircraft could be authorised. These difficulties include international co-ordination agreements, agreements with other administrations to operate base stations within their territories, implications of the maritime and aeronautical licensing regimes, and safety concerns due to interference or misuse. For these reasons, use on passenger ferries and aircraft is not considered as a practical proposition.

5.2.6 Historically, use of licence-exempt spectrum to provide third-party services by way of business has been prohibited in the UK. However, in October 2001 RA consulted on the “Use of licence-exempt spectrum for the provision of public telecommunication services”. The result of this consultation was a change in policy to allow public use of licence-exempt spectrum, where justified, for specific bands on a case-by-case basis. Consequently, on 8 July 2002, the prohibition was removed for the public use of the 2.4 GHz band12 for equipment complying with IR200513. Similarly, on 12 February

11 Source: Mobile Communications, Issue 349, 4 March 2003.12 Statutory Instrument 2002 No.1590, “The Wireless Telegraphy (Exemption) (Amendment) Regulations

2002”.13 UK Radio Interface Requirement 2005, “Wideband transmission systems operating in the 2.4 GHz ISM band

and using spread spectrum modulation techniques”.

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2003, public use of bands at 5150-5350 MHz and 5470-5725 MHz was permitted for equipment complying with IR200614.

Question 6 If your answer to question 4 is yes, should the use of this spectrum for the provision of public services be allowed?

Question 7 If your answer to question 6 is yes, specifically what kinds of public-service offerings do you anticipate will develop? Estimates of potential market size and anticipated penetration would also be useful.

5.3 Maintaining the status quo

5.3.1 As indicated in paragraph 4.3, the entire GSM 1800 spectrum (1710-1880 MHz) was identified by WRC-2000 as potential future expansion spectrum for 3G/IMT-2000. It is anticipated that the spectrum will migrate to 3G use in the longer term, after additional spectrum at 2500-2690 MHz has been made available around the year 2008.

5.3.2 Allocating the spectrum to GSM use, especially on a licence-exempt basis, could cause difficulties for future migration. Once spectrum has been released for licence-exempt services, it is very difficult to change its use at a future date as it is almost impossible to recall equipment from users when there are no records of who and where they are.

5.3.3 Current UMTS15 systems use a channel spacing of 5 MHz. Allocating approximately 2 x 3 MHz of spectrum would introduce additional fragmentation in the band, which could hinder efficient migration in the future.

5.3.4 For the above reasons, it might be better in the longer term not to release the spectrum at this stage but to keep it to one side to assist in future migration to 3G.

5.3.5 Another factor that should be borne in mind is that the current spectrum is currently used for Testing and Development (T&D). Temporary T&D licences can be issued in this spectrum with minimal impact to existing users. As the spectrum forms part of the GSM 1800 band and is close to 3G bands, it is particularly useful for organisations developing cellular systems.

Question 8 Do you consider it prudent not to release the spectrum at this stage but to keep it unassigned, thus assisting future migration to 3G and facilitating T&D work?

5.4 Time-limited use of the band

5.4.1 Given the anticipated migration of the GSM 1800 spectrum to 3G use, it may be prudent to limit any proposed future use of the band to, say, 10 years, so that future migration is not hindered.

5.4.2 A disadvantage of making the spectrum available for licence-exempt GSM use is that, once a band has been released for licence-exempt use, it is very difficult to recover it in the future (to migrate to 3G). However, as indicated in paragraph 5.3.3, an

14 UK Radio Interface Requirement 2006, “Short range, broadband, data services (HIPERLAN) operating in the frequency range 5-6 GHz”.

15 Universal Mobile Telecommunication System.

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advantage of licence-exempt GSM use of the band is that operators/service providers will be able to make use of the existing base of GSM handsets. This might effectively impose a self-limitation on future licence-exempt use, since the number of 2G handsets available for use in this band will fall as GSM generally migrates to 3G.

Question 9 Do you consider it necessary to limit future use of the spectrum for a set period, to ensure that future migration to 3G is not hindered?

Question 10 If your answer to question 9 is yes, what period do you consider is appropriate?

5.5 Technology neutrality

5.5.1 It should be noted that the conclusions of ERC Report 100, which indicate that a guard band between the GSM 1800 and DECT spectrum is no longer necessary, are valid only on the assumption that GSM technology will utilise the spectrum. If other technology were employed, this would raise adjacent-band compatibility issues for both the DECT and the GSM 1800 edges of the band. For this reason, only options based on the use of GSM technology are being considered in Sections 5.1 and 5.2 of this consultation.

5.5.2 However, one of the main themes of the Independent Review of Radio Spectrum Management can be summarised as follows:

In the interests of maximising the economic and social value of the spectrum, internationally agreed frequency allocations and national frequency assignments should make spectrum available for commercial use subject to a minimum of restrictions on technology and services.

5.5.3 Given the above discussion, it would be interesting to hear views on the possibility of making the spectrum available in a technology-neutral way (either for wide-area public use or for short-range, low-power, licence-exempt use) that does not invalidate the conclusions of ERC Report 100.

Question 11 Is it desirable and practical to make the spectrum available in a technology-neutral way, either for wide-area public use or for short-range, low-power, licence-exempt use?

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6 SUMMARY OF QUESTIONS

Question 1 Given the other potential uses outlined in this document, do you consider it most appropriate to make the spectrum available for wide-area public use?

Question 2 If your answer to question 1 is yes, do you consider it most appropriate for the spectrum to be used to supplement the spectrum of the existing GSM operators, or to be made available for potential new GSM operators on a regional or national basis?

Question 3 If your answers to questions 1 and 2 are yes, do you consider it most appropriate for the spectrum to be awarded via an auction process?

Question 4 Given the other potential uses outlined in this document, do you consider it most appropriate to make the spectrum available for short-range, low-power GSM use on a licence-exempt basis?

Question 5 If your answer to question 4 is yes, what kinds of application do you anticipate will develop? Estimates of potential market size and anticipated penetration would also be useful.

Question 6 If your answer to question 4 is yes, should the use of this spectrum for the provision of public services be allowed?

Question 7 If your answer to question 6 is yes, specifically what kinds of public-service offerings do you anticipate will develop? Estimates of potential market size and anticipated penetration would also be useful.

Question 8 Do you consider it prudent not to release the spectrum at this stage but to keep it unassigned, thus assisting future migration to 3G and facilitating T&D work

Question 9 Do you consider it necessary to limit future use of the spectrum for a set period, to ensure that future migration to 3G is not hindered?

Question 10 If your answer to question 9 is yes, what period do you consider is appropriate?

Question 11 Is it desirable and practical to make the spectrum available in a technology-neutral way, either for wide-area public use or for short-range, low-power, licence-exempt use?

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Appendix ACURRENT GSM 1800 AND DECT ASSIGNMENTS

1805

.1

1810

.9

1816

.7

1846

.7

1876

.7

1880

.0

1900

.0

mm

O2

2 x

5.8

MH

z

Vo

daf

on

e 2

x 5

.8 M

Hz

T Mobile 2 x 30 MHz Orange 2 x 30 MHz DECT 20 MHz

1710

.1

1715

.9

1721

.7

1751

.7

1781

.7

1785

.0

Base Transmit

Base Receive

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Appendix BTECHNICAL CONSIDERATIONS

B.1 The 1876.7-1880.0 MHz band currently serves as a guard band to protect GSM 1800 systems against interference to or from DECT systems. The 1781.7-1785.0 MHz band is currently unassigned.

B.2 In June 1994, the ERC published Report 31 on “Compatibility between DECT and DCS 1800”. This report indicated that the minimum frequency separation required between DCS 1800 (now termed GSM 1800) and DECT carriers is 5 MHz. The report was the result of both theoretical studies, based on ETSI specifications, and limited practical measurements carried out under laboratory-controlled conditions. 1.8 MHz of this separation is provided for within the DECT band (due to the location of the first DECT carrier at 1881.792 MHz); hence the need for a further 3.3 MHz of guard band within the GSM 1800 allocation.

B.3 Subsequently, in February 2000 the ERC published Report 100, “Evaluation of DECT/GSM 1800 compatibility”. This report, a revision of Report 31, was again the result of both practical and theoretical studies. Report 100 assessed the potential interference with real equipment, as well as with specification values on the basis of minimum coupling loss (MCL), enhanced minimum coupling loss (E-MCL) calculation and Monte Carlo (MC) analysis. It recommended that a guard band is not required, although specific local restrictions may be needed for the GSM sub-band 1878-1880 MHz. Section 7 of the report recommended certain mitigation measures to reduce interference between GSM 1800 and DECT systems, such as:

the GSM BCCH control channel should not operate within the 1878-1880 MHz band;

GSM can escape temporary interference close to the DECT band edge by intra-cell handover, if this escape is made to another carrier more distant from the DECT band; and

DECT wireless local loop (WLL) equipment that exceeds the minimum blocking requirement should be used.

See ERC Report 100 for further details.

B.4 Implementation of GSM 1800 spectrum varies from country to country in Europe. Many countries have implemented only a proportion of the available spectrum, and a few have not implemented it at all. Of those that have implemented the whole of the available spectrum, or at least a large proportion of it, the guard band between DECT and GSM 1800 varies considerably. Some countries (such as Belgium, France, Italy and Luxembourg) have either no guard band or a minimal guard band (i.e. one 200 kHz GSM channel). Other countries (such as Portugal, Spain and the UK) have a 3.3 MHz guard band. Yet other countries have allowed for still different guard bands. (Source: ECC Report 10, Annex 516.)

16 ECC Report 10, Interim report from the ECC to the CE, “Frequency usage to facilitate a co-ordinated implementation in the Community of third generation mobile and wireless communication systems operating in additional frequency bands as identified by the WRC-2000 for IMT-2000 systems”, Paris, March 2002.

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Appendix CTHE CONSULTATION CRITERIA

1 Timing of consultation should be built into the planning process for a policy (including legislation) or service from the start, so that it has the best prospect of improving the proposals concerned, and so that sufficient time is left for it at each stage.

2 It should be clear who is being consulted, about what questions, in what timescale and for what purpose.

3 A consultation document should be as simple and concise as possible. It should include a summary, in two pages at most, of the main questions it seeks views on. It should make it as easy as possible for readers to respond, make contact or complain.

4 Documents should be made widely available, with the fullest use of electronic means (though not to the exclusion of others), and effectively drawn to the attention of all interested groups and individuals.

5 Sufficient time should be allowed for considered responses from all groups with an interest. Twelve weeks should be the standard minimum period for a consultation.

6 Responses should be carefully and open-mindedly analysed, and the results made widely available, with an account of the views expressed, and reasons for decisions finally taken.

7 Departments should monitor and evaluate consultations, designating a consultation co-ordinator who will ensure the lessons are disseminated.

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Draft Regulatory Impact Assessment

Use of the 1781.7-1785.0 / 1876.7-1880.0 MHz Bands

for the Provision of GSM 1800 Telecommunications

Services

March 2003

The Radiocommunications Agency is an Executive Agency of the Department of Trade and Industry.

The Agency's website is located at www.radio.gov.uk

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REGULATORY IMPACT ASSESSMENTUse of the 1781.7-1785.0 / 1876.7-1880.0 MHz bands for the provision of GSM 1800

telecommunications services

Purpose and intended effect

1 The proposed change in policy is to make available the bands 1781.7-1785.0 / 1876.7-1880.0 MHz, the second of which is currently maintained as a guard band between GSM 1800 and DECT services. (The 1781.7-1785.0 MHz band is currently unassigned.) The objective is to promote efficient use of the spectrum by allowing potentially valuable services to occupy the released bands.

Options

2 Three options are being considered in this consultation:

Option 1 – Make the spectrum available on a national or regional basis, either to the existing GSM operators or to new entrants, for the provision of public mobile telecommunications services.

Option 2 – Make the spectrum available for short-range, low-power use on a licence-exempt basis, either for third-party public services or for self-provided use.

Option 3 – Maintain the status quo, with the spectrum remaining unassigned.

3 If either of Options 1 or 2 is chosen, further consultation will determine how the released spectrum is to be allocated and, in the case of Option 2, to which type of service.

Risk assessment

4 ERC Report 100 and RA’s own analysis suggest that a 3.3 MHz guard band between GSM 1800 and DECT is no longer required. RA has received a number of requests from industry, expressing interest in using this spectrum to provide a range of telecommunications services; this indicates that demand for spectrum exceeds supply in this band. If this spectrum is not made available, firms will not be able to provide potentially valuable services to consumers.

5 However, there are also risks in making the guard band available. For example:

the risk of radio interference between users may require specific local restrictions for the GSM sub-band 1878-1880 MHz, which could limit the potential use of the released spectrum; and

the Government expects that the entire GSM 1800 band will be refarmed for 3G use in the longer term. Releasing the guard bands for use now could make it more difficult to co-ordinate the migration of 3G services in the future.

6 The risks associated with each option are identified in the table below, together with the costs and benefits.

Summary of the costs and benefits

7 At this stage of the consultation process, it is not possible to give detailed calculations of the costs and benefits of each option. However, this section summarises the main

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elements that will need to be quantified in order to decide between the options. It also identifies the risks to those costs and benefits, which could form the basis of a sensitivity analysis giving ranges for the likely costs and benefits of each option.

Option 1: Wide-area public use

Option 2: Licence-exempt use

Option 3: Status quo

Benefits Cost reductions if the spectrum is given to existing operators.

Benefits of increased competition (i.e. lower prices and improved service) if new entrants are accommodated.

Economic value of new services, including possible public-service benefits.

Easier to migrate the GSM 1800 bands to 3G.

Vacant spectrum remains available for testing.

Costs Cost of rollout if the spectrum is offered to new entrants.

Cost to existing operators will be minimal if they are offered the spectrum, as the infrastructure already exists.

Cost of retrieving the spectrum if the GSM 1800 bands are refarmed to 3G.

Cost of deploying equipment (which may be low if people can use GSM equipment).

Cost of retrieving the spectrum if the GSM 1800 bands are refarmed to 3G.

Opportunity cost of not using the vacant spectrum.

Risks The small quantity of spectrum may not support new entrants.

Uncertainty over the timing of 3G refarming may affect the cost of retrieving the spectrum.

Possibility of radio interference from overuse of licence-exempt spectrum.

Uncertainty over demand from users, given the previous release of the 2.4 GHz band for licence-exempt public use.

Uncertainty over 3G refarming.

3G refarming may be delayed.

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Business sectors affected

8 Many sectors of the economy and consumers would benefit from the suggested change in policy, including:

the telecommunications operators;

radio equipment manufacturers and suppliers;

the electronic consumer market;

the retail consumer market; and

telecommunications consumers.

9 Small users could benefit particularly from the release of licence-exempt spectrum under Option 2.

10 The costs of using the released spectrum under Options 1 and 2 would fall directly on radio operators. However, they would also stand to benefit from charging for their services, and any use of the new spectrum would be voluntary. There would be no costs falling on third parties, provided that interference does not increase outside the released bands.

Consultation

11 RA is to carry out a national consultation exercise into the use of the 1781.7-1785.0 / 1876.7-1880.0 MHz band for provision of GSM 1800 telecommunications services on 28 April 2003. Consultees are to be given 12 weeks to reply.

Monitoring and evaluation

12 The success of implementing any of the options could be monitored and evaluated in part by monitoring the extent of use of the released spectrum.

13 Option 1 could also be evaluated by monitoring the profitability of any new entrant and the prices charged to customers as a result of introducing new spectrum. It would probably not be possible to monitor cost savings if the spectrum were assigned to an existing operator.

14 The success of Option 3 could be assessed in part by the extent of use of the spectrum for T&D. Whether the spectrum could be refarmed – and, if so, its cost – would be another criterion for success.