UK Broadband response to ACMA consultation

Transitioning the 3.5GHz band for future opportunities

COMMENTS OF UK BROADBAND LTD

UK Broadband Ltd (UKB) is the UK's largest commercial holder of national radio spectrum suitable for 4G mobile services and fixed wireless solutions. This spectrum includes 124MHz between 3400 and 3800MHz. UKB operates a London based TD-LTE internet service (Relish) using this spectrum and is presently rolling out this service across the UK.

UK Broadband hereby submits its comments in response to the ACMAs consultation on the transitioning of 3.5GHz licensing and the future opportunities presented by this important global mobile broadband frequency band.

In particular we are keen to comment on the following questions posed by the consultation:

The ACMA welcomes commentary from interested parties on the implications for Australia of the emerging international arrangements in the 3.5 GHz band.

In particular, the ACMA invites views on whether the current lack of alignment with internationally harmonised standards for the band is considered a problem for current and aspirant users of the band.

The ACMA welcomes any additional information that respondents may be able to provide on technologies and equipment that is being made available in the 3.5 GHz band.

The ACMA welcomes commentary on whether stakeholders currently have a preference for TDD or FDD arrangements in the 3.5 GHz band

Introduction

We understand that the ACMA identified the 3.5 GHz band as a potential mobile band in its 2011 paper Towards 2020Future spectrum requirements for mobile broadband.[footnoteRef:1] Since then there has been significant international developments concerning this band which the ACMA has reflected in changing the status of mobile services in the 3.5 GHz band from secondary to primary in the Australian Radiofrequency Spectrum Plan 2013 (ARSP 2013) to provide additional flexibility in the use of the band[footnoteRef:2]. [1: The paper is available on the ACMA website. ] [2: The ARSP 2013 is available at www.comlaw.gov.au/Details/F2012L02523. It is noted that section 7 of the ARSP states that services operating under a spectrum licence are considered primary unless otherwise specified on the licence. ]

Given the increasing consumption of mobile data and the scarcity of spectrum at lower frequency bands (sub 3GHz), UKB believes that the highest economic value for 3.5GHz can be derived from using the band for mobile broadband services based on International standards. We also believe that the adjacent 3.6GHz (Band 43 designated by the 3GPP) is equally important with the two bands forming a contiguous block of spectrum for current LTE services and future 5G technologies. Moreover, given then increasing momentum of TD-LTE at these bands, we believe that TDD will become the de-facto standard for network deployments at 3.5/3.6GHz.

International harmonisation of the 3.5/3.6GHz bands

Since the WRC-07 meeting in 2007, International Telecommunications Union members have agreed to allocate 3400-3700MHz across all three ITU regions to mobile or IMT[footnoteRef:3] use. This allocation agreement covers most countries of the world as stated in radio regulations (RR) 5.430A, 5.431A, 5.432B and 5.433A. Current regulations resulting from WRC-12 allocate 3400-4200MHz to mobile use. It is expected that deeper global agreement to use bands in this range for IMT use will be an outcome of ITU-R WRC-15 in 2015. [3: The term IMT covers IMT-2000 (e.g. LTE & WiMAX 802.16e) and IMT-Advanced systems (e.g. LTE-Advanced & WiMAX 802.16m) ]

Region 1

In Europe, on December 9, 2011 the 48 pan-European member countries[footnoteRef:4] of the CEPT/ECC passed the ECC Decision (11)06 resolution (amended March 14, 2014)[footnoteRef:5] harmonising arrangements for 3400-3800MHz across the wider European continent. This decision designates this spectrum to mobile/fixed communications networks (MFCN) with TDD the preferred duplex mode for 3400-3600MHz (see Figure 1) and compulsory for 3600-3800MHz. [4: http://www.cept.org/cept/membership-and-observers] [5: http://www.erodocdb.dk/docs/doc98/official/pdf/ECCDec1106.pdf]

3400 MHz

3600 MHz

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

Figure 1 Preferred TDD frequency arrangement for 3400-3600MHz

Figure 2 Alternative FDD frequency arrangement for the 3400-3600MHz

Region 3

In China, the Ministry of Industry and Information Technology (MIIT) has conducted co-existence studies and field tests to evaluate the compatibility between TD-LTE and fixed satellite services (FSS) and we understand that co-existence between Band 42 TD-LTE and satellite services have been proven utilising:

Shielding

Beamforming and interference nulling

Power Control

We understand that the MIIT believes that 3.5GHz is one of the most important spectrum bands for LTE/LTE-A and that spectrum release for LTE-TDD will happen in the near future.

In Japan, introduction of LTE-Advanced systems to 3400-3600MHz band was studied during 2012-2013. The technical requirements such as the coexistence with incumbent systems (satellite, and microwave links) were concluded. Spectrum is being allocated to operators in Japan and it is understood that these operators are planning on imminent launches of LTE-A TDD in 3.5GHz commercial services.

Figure 3 Japanese operator plans for LTE-TDD at 3.5GHz

In South Korea although some capacity in the 3.5-3.7GHz range is used for fixed satellite services, the Korean Communications Commission plans to release at least 160MHz of capacity at 3.5GHz for mobile broadband services by 2016 as part of its Mobile Gwanggaeto Plan[footnoteRef:6]. Both TDD and FDD (2x80MHz) options in 3400-3600MHz are considered to meet the capacity target. [6: http://eng.kcc.go.kr/user.do?mode=view&page=E02020000&dc=E02020000&boardId=1053&cp=1&boardSeq=35032]

Region 2

In the US, the FCC[footnoteRef:7] envisions 3.5/3.6 GHz as an innovation band utilising a Three-Tier Spectrum Access framework. [7: https://www.federalregister.gov/articles/2014/06/02/2014-11732/commission-seeks-comment-on-shared-commercial-operations-in-the-3550-3650-mhz-band]

The FCC proposes that the first tier, Incumbent Access, would include authorized federal users. These incumbents would be afforded protection from all other users in the 3.5/3.6 GHz Band.

The second tier, Priority Access (PA), would include critical use facilities, such as hospitals, utilities, government facilities, and public safety as well as non-critical entities such as operators that would be afforded a quality-assured access the 3.5/3.6 GHz Band. TD-LTE would be a good candidate for this tier.

The third tier, General Authorized Access (GAA), would be authorized to use the 3.5 GHz Band opportunistically. GAA users would be required to accept interference from Incumbent and Priority Access tier users but have to avoid causing any harmful interference to Priority Access Licensees and Incumbent Access tier users.

UKB is encouraged and pleased to see progress towards wider use of 3.5GHz spectrum in the USA. We agree that this spectrum has an important part to play in relieving spectrum scarcity and the FCCs drive to address wireless coverage and capacity issues. The importance of and need to protect incumbent spectrum users is understood as is the desire to innovate with regard to spectrum sharing. However, we have responded to the FCCs consultation and urged it to consider how this innovation can embrace International Standards that are the basis of services already provided in the 3.5GHz band by operators worldwide.

The key points made by UKB in its responses to the FCCs proposals are as follows:

I. Consideration of the needs of licensees in the United States already using the 3650-3750MHz band (primarily WiMAX users).

II. The rapid global trend of migration from WiMAX to 3GPP LTE / LTE-Advanced and in particular the growth of new TD-LTE networks in the band.

III. The lack of dynamic spectrum access functionality in existing 3GPP standards and the need for them if the aims of the Spectrum Access System (SAS) proposed by the FNPRM (Subpart F) are to be achieved.

The FCC concept of a licensing regime that protects incumbent users and permits Priority Access Licensing (PAL) licensee protection from GAA users is supported. However, UKB has stressed in its response to the FCC that the PAL scheme proposed is not in the best interests of United States consumers, manufacturers and existing licensees. Further it is not in the interests of 3.5GHz licenced operators and equipment vendors as the approach is contrary to that used in the existing and growing 3.5GHz ecosystem. This argument is based on:

I. The need to support Spectrum Access System (SAS) functionality. This is not consistent with current or proposed WiMAX or 3GPP standards. The required hardware and software solutions would not be interoperable with the current WiMAX and developing ecosystem of LTE devices.

II. The use of SAS implies that a PAL licensee may be required to reduce power output or desist from transmission entirely should the SAS dynamic channel allocation mechanism determine that a neighbouring license has priority. This will affect an operators ability to guarantee service and could be a disincentive to invest in network roll-out.

III. The combination of small granular (census tract) licensing areas and short, annual licensing term is likely to be a disincentive to invest capital in equipment and deployment in the US and globally.

Moreover, UKB considers that some guaranteed fixed channel spectrum should be licensed for longer term use across wider geographies particularly for use with small cell deployments to the benefit of US consumers. Such licenses would not require the use of SAS but would be restricted in terms of geography and power output to protect incumbents. Additionally, like incumbents, these licenses would be protected against interference caused by the proposed GAA and PAL users due to their use of the SAS database which would reflect a licensees fixed allocation.

International Standards

The dominant standards for equipment used in these bands are IEEE WiMAX 802.16d and 802.16e and 3GPP LTE and LTE-Advanced. Whilst roll-out of WiMAX based equipment continues, WiMAX standards development and adoption of 802.16m has slowed as LTE and LTE-Advanced traction has increased. The 3GPP has formally sanctioned 3.4-3.8GHz bands for use. Since 2011 the TDD bands (42 & 43) have been included. Relevant bands defined for LTE-Advanced Rel-10 (TS 36.101)[footnoteRef:8] are as shown in Figure 4. However, note that the overwhelming investment focus and deployment is centred on TDD rather than FDD (3GPP Band 22) and we firmly believe that TD-LTE will become the de-facto standard for these bands. [8: http://www.3gpp.org/DynaReport/36101.htm]

LTE Band

Duplex method

Frequency Allocation

42

TDD

3400 3600 MHz

43

TDD

3600 3800 MHz

22

FDD

3490 MHz UL / 3510 3590 MHz DL

Figure 4: LTE Advanced Rel-10 bands between 3.4 and 3.8GHz

International 3.5/3.6GHz deployments

3.5/3.6GHz bands have been deployed by over 100 operators globally. Many of these operators have deployed WiMAX in the past but are increasingly migrating to TD-LTE.

With regard to TD-LTE deployments, there is an increasing momentum around 3.5/3.6GHz with over twenty contracts awarded to equipment manufacturers as shown in Figure 5.

Figure 5: Recent TD-LTE contracts at 3.5/3.6GHz (Source: Global TD-LTE Initiative)

UK Broadband

UK Broadband launched its Relish Mobile and Fixed Wireless Broadband Service on June 4th 2014 (see Figure 6) using TD-LTE at 3.5GHz and 3.6GHz. UK Broadband selected Huawei as its main equipment vendor and Huawei support has ramped up over the past 12 months such that 3.5GHz infrastructure is now part of Huaweis standard product roadmap.

UKB currently supplies internal and external fixed CPE as well as personal Wi-Fi hotspot routers. UKB expects Huawei to launch a fully commercial multi-band smartphone containing 3.5GHz later in 2014 which UKB expects to offer on its network in 2015.

The UKB launch footprint covers central London and includes macro-cells, micro-cells and small-footprint single sector hardware. Next generation small footprint radio equipment from Huawei (Atom Cell) and Airspan (Airsynergy 2000) will be deployed throughout 2014.

Figure 6 UK Broadband Relish 3.5GHz mobile broadband

Global equipment ecosystem in the 3.5/3.6 GHz band

Deployment of mature WiMAX 802.16e continues but as TD-LTE grows chipset vendors, equipment vendors and operators are migrating from WiMAX to TD-LTE or building new TD-LTE networks.

3.5GHz TD-LTE equipment and end user devices are available from multiple vendors with some chipsets offering software only upgrade from WiMAX to TD-LTE. In August 2013, Innovation Observatorys 3.5/3.6GHz LTE TDD Ecosystem Report[footnoteRef:9] identified availability of 16 end user devices for use in Bands 42 and 43. This same report forecasts that shipment of 3.5GHz capable devices will be between 5-15% of global device shipments (see Figure 7). [9: http://www.lte-tdd.org/d/file/Resources/pub/2013-11-22/4989a6d1b9ed435fa6ec20f5d291f547.pdf]

Figure 7 Forecast of 3.5GHz device shipments (Source: Innovation observatory)

Technology ecosystem

A wide range of chipsets supporting TD-LTE at 3.5GHz are now available. Chipset vendors that are known to have 3.5GHz capability for their TD-LTE chipsets include Huawei/Hisilicon, Sequans and Altair Semiconductor. Other important chipset providers such as Qualcomm and Intel will have 3.5GHz TD-LTE chipsets ready in 2014/2015.

Availability of devices that can support TD-LTE remains growing. In late 2013, multimode personal hostpot routers (GSM/UMTS/TD-LTE) have become available serving many significant markets. Furthermore, during MWC 2014, Huawei showcased the worlds first 3.5GHz TD-LTE smart phone, which was expected to be launched in late 2014 and which UKB expects to utilise on its Relish network.

According to the GSA[footnoteRef:10] statistics, there are 24 devices in the market in mid-July 2014. Details for some selected devices are presented in Figure 8. [10: http://www.gsacom.com/]

Vendor

Device type

Device name

Frequency bands supported

FIC

Mobile tablet

Elija TF9300

TDD Band 42 and 43

Greenpacket

Router

DA-235

TDD 2300, TDD 2600, TDD Band 42 and 43

Huawei

Router

B2268A

TDD 1900, TDD 2300, TDD 2600, TDD Band 42 and 43

Huawei

Mi-Fi

E5776s

TDD Band 42 and 43, FDD 2600, UMTS 850/900/2100

Mitrastar

Router

Outdoor CPE

TDD Band 42 and 43

Netcomm

Router

WNTD 4243

TDD 2300, TDD2600, TDD Band 42 and 43

Figure 8 Mulitmode/multiband devices at 3.5/3.6Hz

The status of the network equipment market is similar to the status of the device market. A number of International vendors of radio network equipment support TD-LTE base stations at 3.5GHz, including Huawei, Nokia, Datang Mobile and Airspan.

Small Cells

We believe Small Cell deployment is a highly likely use case for the 3.5/3.6GHz bands exemplified by early small cell deployments (for example Airspan[footnoteRef:11]) and device chipset vendors such as Qualcomm who see 3.4 to 3.8GHz emerging as a new Small Cell band. [11: http://www.airspan.com/2014/01/30/airspan-and-b%E2%80%A2lite-successfully-deploying-lte/]

Figure 9: TD LTE 3.4 to 3.8GHz emerging as a new small cell band. Source: Qualcomm[footnoteRef:12] [12: http://www.qualcomm.com/media/documents/files/lte-tdd-the-global-solution-for-unpaired-spectrum.pdf]

The increasing consumption of mobile data via proliferation of Smartphones and tablets especially in high footfall metro areas, has led to Qualcomm and other leading vendors proposing 3.5/3.6GHz as an ideal Small Cell solution.

Conclusion

UK Broadband is supportive of the wider use of 3.5GHz in Australia and globally. The company believes that with the increasing consumption of mobile data on smartphones and tablets, that the 3.5/3.6GHz bands have become increasingly valuable and important for the delivery of high capacity mobile broadband.

We believe that the greatest economic value from the bands can be derived through the deployment of the TD-LTE global standard which is being adopted by significant operators across the globe. There is wide global agreement through the ITU that IMT-Advanced, which in practice means 3GPP LTE-Advanced, is the technology for use in this band. With CEPTs backing TD-LTE looks set to dominate the band globally as opposed to FDD arrangements (i.e. 3GPP Band 22).

We also believe that long tenure licensing over large geographic/demographic areas is appropriate in this band as this is the only way that significant operators will invest appropriate capital for network deployment for the benefit of Australian consumers.

The deployment of TD-LTE for mobile services in Europe, USA, China, Japan and the UK is leading to

significant volumes at 3.5/3.6GHz which in turn is leading to greater choice and lower costs for

consumers.

We believe that the ACMA can stimulate adoption of TD-LTE by setting the right regulatory

environment which will lead to major benefits for the Australian consumer in terms of the availability of higher mobile broadband speeds and services.

UK Broadband wishes to thank the ACMA for consideration of the matters raised.

For and on behalf of UK Broadband Ltd:

Name

Role

Nicholas James

CEO

Signature

Date

29 July 2014

1

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

Uplink

Duplex Gap

Downlink

3410 MHz

3490 MHz

3510 MHz

3590 MHz

3400 MHz

3600 MHz