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Orange Document Transcript

  • 1. Orange response to ‘consideration of possible frequency plans for the 3G expansion spectrum 2500 to 2690 MHz, October 2003 Orange is pleased to respond to the Radiocommunication Agency’s (RA) consultation on the ‘consideration of possible frequency plans for the 3G expansion spectrum’. As a global mobile telecommunication provider, Orange is involved in consultations on the use of the 2500 to 2690 MHz expansion band for UMTS in national, European and international fora. Orange is currently trialling UMTS equipment in the UK and plans to launch a commercial service by Q3 2004. Question 1 Should the 2500 to 2520 MHz and 2670 to 2900 MHz sub-bands be designated for the satellite or terrestrial component of IMT-2000 within Europe? Orange believes that the sub-bands 2500 to 2520 MHz and 2670 to 2900 MHz should be designated exclusively for the terrestrial component of IMT-2000 within Europe. Orange recently carried out a study1 to consider both the market and spectrum needs for the satellite component of IMT2000 until 2010. The objective of the first part of the study was to provide an analysis of:  the number of users who have a current need for mobile satellite services (MSS) and the revenues of the market for MSS;  the prior MSS forecasts in comparison with the real MSS subscribers and revenues evolution, and  the key factors explaining the gap between those projections and the real evolution. The objective of the second part of the study was to provide forecasts for the MSS market up to 2010. The conclusions of the report found that the conservative forecasts of the market size, and hence the requirement for satellite spectrum, are the more realistic at this time. Orange expects that, given the current financial condition of two MSS operators2 that most, possibly all, of the current MSS applicants will not ultimately launch and provide service in MSS band allocations. In addition, it was found that, even if the optimistic scenario tends to be more realistic, the predictable subscriber and revenue evolutions by 2010 derived from forecasts are much lower than previous MSS forecasts (which partially determined the previous MSS spectrum allocation in the core band). By the end of 2002, there were 1229 million 2G/ 3G mobile users worldwide compared to only 0.645 million MSS users within around 375 MHz allocated to mobile services and 159 MHz for MSS respectively. This equates to over 3 million subscribers per MHz for mobile services and approximately 4,000 subscribers per MHz for satellite services. Orange believes that satellite UMTS services will be a complement to terrestrial UMTS for the extension of coverage in remote areas, although we believe that the 1 Available on request 2 Iridium and Globalstar
  • 2. development of complementary services, such as handheld Internet access and videoconferencing, is likely to remain limited. In addition, we would expect that these complementary offerings would serve niche markets, not consumer markets, and that there will not be a high demand for satellite UMTS in remote areas. In the UMTS core band, only two satellite UMTS projects are envisaged in the 2x30 MHz already allocated to MSS (which includes the ICO project that has been frozen due to financial problems). On the other hand, more than 120 terrestrial UMTS licences have been awarded worldwide. Considering the bands already allocated to mobile satellite below 2.5 GHz, there is no reasonable market expectation that would justify additional spectrum for MSS. If MSS is to have an allocation for new systems, it should concentrate on the core band. With the exception of Inmarsat, who will have access to an extension band at 1.5 GHz (WRC-03 decision), the mobile satellite systems support low traffic volume and already have access to an additional band available at 2GHz. Orange therefore believes that considering the bands already allocated to the mobile satellite below 2.5 GHz, there is no reasonable market expectation that would justify additional spectrum for MSS. With the exception of Inmarsat, who will have access to an extension band at 1.5 GHz (WRC-03 decision), the mobile satellite systems support low traffic volume and have access to an additional band available in the 2GHz core band. Question 2 How much emphasis should Europe place on frequency arrangements that could be partially implemented on a global basis? Orange believes that harmonisation of both spectrum and frequency plans are important for the development of mobile applications. Harmonisation of spectrum enables roaming, interoperability and economies of scale in the production of equipment, all of which have been amply demonstrated by the success of GSM. This harmonisation includes the recognition at ITU level of the association of a frequency band with one particular service or application, a technical standard (including the radio interface) and a common frequency arrangement. The first step of harmonisation for the UMTS expansion bands was achieved at WRC-2000 through the global identification of the band 2500-2690 MHz for IMT-2000. The second step is the harmonisation of the frequency arrangement. Having harmonisation of frequency arrangements at European level is important for the launch of 3G in this band. If European harmonisation is successful, it is then possible that other countries outside Europe, which are currently using other services in this band, may, in the future, refarm this band to align to the European plan. Orange believes that harmonisation of both spectrum and frequency plans are important for the development of mobile applications. Having harmonisation at European level of frequency arrangements is important for the launch of 3G in this band. Question 3
  • 3. Is it practical for the deployment in a particular country to differ from that of its neighbours? In Europe, it is not practical for one country to differ from its neighbours in the deployment of technology. This is mainly due to border coordination and circulation of terminals. The size of the addressable market does not justify the development of specific terminals on a per country basis. Orange believes that European deployment should be harmonised as far as is reasonably practicable. Question 4 What could the spectrum potentially be used for in terms of applications, target markets etc? The band under consultation is an extension band for 3G/ UMTS which aims to provide additional capacity for 3G services. To this end, the applications and the market will be the same as for the core band. However, due to the propagation characteristics of this band, Orange believes that it will be used primarily in dense urban areas. Question 5 What are the anticipated traffic characteristics/ assumptions that should be made on aspects such as asymmetry characteristics and whether more spectrum is required in the ‘downlink’ direction than in the ‘uplink’ direction? Orange is currently trialling UMTS and proposes launching a commercial service during Q3 2004. Whilst there are many exciting ideas, to date it is still unclear whether video telephony or sending and receiving files on the move, or another service entirely, will be the ‘killer’ application. This obviously determines whether services will be asymmetric or not and we will need to wait for the commercial uptake of UMTS services to understand requirements fully. However, it is clear that at this juncture that we should not exclude any deployment option as flexibility needs to be retained until the level of certainty about the range and nature of services has improved. Orange believes that we should not exclude one technology as, at this point, flexibility needs to be maintained. Question 6 Should the core 3G spectrum – both the licensed and the unlicensed (self-provided) bands – be considered for potential pairings with the 2500 to 2690 MHz band, or should they be treated separately? Orange believes that should be no change to the current channelling arrangements in the core 3G spectrum. Orange does not support any change to the existing spectrum arrangement in the core band, such as pairing with the 2500-2690 MHz.
  • 4. Orange has submitted a detailed consideration of this question in our response to the accompanying RA consultation paper ‘use of the 2010 MHz to 2025 MHz band for the provision of 3G telecommunication services’. Orange believes that should be no change to the current channelling arrangements in the core 3G spectrum. Question 7 Do the boundaries between the different ‘elements’ within the expansion spectrum need to be fixed, apart from the position of the minimum duplex separation band and the duplex direction? For example, does the boundary between FDD and TDD/ downlink-only need to be fixed? Orange believes that it is necessary to fix the lower and upper endpoint of both the FDD uplink and FDD downlink allocations within this band in order to specify the terminal filter design. Within the FDD downlink, flexibility can be retained in terms of how much of this is for internal pairing and how much is for external pairing. Fixing the endpoints of the FDD uplink and downlink will naturally also fix the allocation for TDD. Question 8 Will all terminals need to support all scenarios for roaming (i.e. FDD, TDD and downlink only) including support for the core 3G spectrum? Orange believes that whilst this is a commercial decision for operators and manufacturers which will be based on market demand, terminals should support at least a minimum number of scenarios. These scenarios should include roaming between both the core bands and the expansion bands in Europe. Subsequent development of the multiple band/ mode phones will then follow as the market develops. However, it is important, that the final decision that is reached under Mandate 5 is compatible with the development of terminals and network equipment, at a reasonable cost and in time (taking into account the deployment of 3G already achieved at the date of use of the 2500-2690 MHz band). Orange believes that whilst this is a commercial decision for operators and manufacturers which will be based on market demand, terminals should support at least a minimum number of scenarios. Question 9 What are your views on the timing of the mandate deliverables, particularly for the final CEPT Report and the ECC Decision? It is clear that the current timescales of the Mandate 5 deliverables are extremely tight: July 2004 submission of an interim report to the Radio Spectrum Committee (RSC). This report will give initial proposals and strategies and comment on the progress of the work, also highlight any issues with the timing of the Mandate.
  • 5. November 2004: submission of the final CEPT report to the RSC and adoption of the ECC Decision for public consultation. March 2005: final approval of the ECC Decision by the ECC. Orange supports the CEPT timing. However, a decision at the ECC meeting in March 2005 is needed to ensure that equipment can be developed by 2008-2010. In its response to Question 1 of this consultation, Orange clearly stated that it does not believe that there is any additional requirement for satellite UMTS spectrum. Orange believes that only by reaching this decision now, along with a minimum scenario clarifying the width and position of the FDD uplink and downlink block (as outlined in the response to Question 7 above), will the CEPT timescales be achieved. Orange believes that only by reaching a decision in March 2004, which includes a minimum scenario clarifying the width and position of the FDD uplink and downlink block will the CEPT timescales be achieved Question 10 What frequency arrangements would you like to see in the 2500 to 2690 MHz band? Alternatively, what options should be retained for consideration and on what basis? Orange believes that at this point, before the commercial launch and mass market of UMTS, we should not be constrained nor exclude any of the technology options that are outlined in the consultation paper. For example, Orange is currently trialling TDD equipment and if it is this technology that provides key services in the future, we may require access to additional spectrum. Orange therefore believes that, currently, options 2, 6 and 7 are not acceptable ‘end solutions’ as they would exclude one or other of the technology solutions (although this does not necessarily mean that they will not become preferable solutions as the market matures). Likewise, internally paired FDD spectrum should also not be excluded. During the consultation of the spectrum packages prior to the UMTS auction, Orange clearly stated in its response that licensed spectrum packages of 2x10 MHz would only be acceptable for the initial launch of UMTS services and that after this period additional spectrum would be required. The 2.5 GHz expansion band will offer the additional capacity needed for the existing 3G operators and the possibility of an additional new entrant. It is also essential to ensure that, where pairing part of this 2.5 GHz band with the initial IMT-2000 band at 2 GHz, that replacement of the 3G base stations already deployed will not be necessary. Orange therefore currently believes that options 4 and 5 are not acceptable solutions. In conclusion, at this stage, Orange supports scenarios 1 and 3 as both enable the internal pairing of FDD spectrum and access to additional TDD spectrum. -oo0oo-