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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.
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
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
Available on request
Iridium and Globalstar
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.
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.
Is it practical for the deployment in a particular country to differ from that of its
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.
What could the spectrum potentially be used for in terms of applications, target
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.
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
Orange believes that we should not exclude one technology as, at this point,
flexibility needs to be maintained.
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.
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.
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
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
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.
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
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.
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
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
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