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  • 1. RESPONSE FROM GSA - Global mobile Suppliers Association to Directorate General Post and Telecommunication, Indonesia PUBLIC CONSULTATION ON THE RE-ARRANGEMENT OF THE FREQUENCY ALLOCATION FOR 3G/IMT-2000 SERVICES Submitted 15 August 2005 About GSA GSA - the Global mobile Suppliers Association - is the forum for, and represents, the leading GSM/3G suppliers worldwide, and represents over 80% of GSM/3G market share globally. The GSA Executive Committee comprises of the leading GSM/EDGE/WCDMA suppliers - Ericsson, Nokia and Siemens. GSA plays a significant and expanding role in promoting GSM/3G worldwide for the best user experience of mobile voice and advanced mobile data services. Adding value through focused global and regional programs, GSA delivers authoritative, factual, and objective information for the mobile industry including market intelligence, market/technology updates, and latest statistics. GSA advises governments, administrations and policy-makers on the optimum conditions for mobile market developments. Briefings are regularly given to media and analysts. Global programs are complemented by regional activities in Africa, APAC, Europe, and the Americas. GSA is a Market Representation Partner in 3GPP and co-operates with other key organisations worldwide. GSA Global mobile Suppliers Association PO Box 5817, Sawbridgeworth Herts CM21 0AN UNITED KINGDOM Tel +44 1279 439 667 Fax +44 1279 435 443 www.gsacom.com
  • 2. A Opening Remarks The Directorate General Post and Telecommunication (DGPT), Indonesia, seeks responses to its public consultation on the re-arrangement of the frequency allocation for 3G/IMT-2000 services. DGPT is to be congratulated on this initiative, which seeks to ensure the best environment for the continuing successful development of the mobile communications industry in Indonesia. Questions about spectrum and the pursuant business issues require careful consideration and balancing in order that the important decisions to be taken are fully in the interests of consumers, within national and international contexts. GSA - the Global mobile Suppliers Association, representing leading mobile equipment manufacturers and with business experience in Indonesia and globally, is pleased to have the opportunity to study the consultation and to offer our views in this submission. Our key concern is for the successful development of the mobile communications industry, with regard to the benefits it brings to consumers, enterprises, teledensity and the economy as a whole. The shift to 3G is well advanced now in Asia, Europe and around the world, and is highly relevant to Indonesia today. We are most concerned that the path to 3G would be severely compromised if existing WLL services, which operate in the US PCS 1900 band, are not relocated outside of the internationally agreed 3G/IMT-2000 spectrum. The issues and concerns are explained in this submission, with detailed explanation given in Annex 1. Wireless communications, and GSM in particular, is making a very important contribution to raising teledensity and telephone usage in Indonesia. It is vital therefore that any decisions which are taken will ensure that the industry continues to grow, and is sustainable for investors and other players, ensuring that Indonesia can participate fully in the global 3G mobile services market, to ensure future investment, economic development and prosperity. Our responses to the DGPT Questionnaire are provided in Annex 2. B The Shift to 3G is Happening Now Globally Mobile operators globally are evolving their businesses to exploit 3G technologies, ensuring: • the best, most consistent user experience of voice and data-enabled services • improvements in network capacity to support a truly mass market for voice services, at lowest cost of delivery • faster data speeds and related performance improvements enabling delivery of exciting non-voice services such as rapid file transfers, Internet access, audio/video streaming etc., to drive productivity gains for enterprises, expansion/consumption in the services sector, and revenue growth for network operators. The International Telecommunication Union (ITU), an international organization within the United Nations where governments and the private sector co-ordinate global telecom networks and services, attaches the highest priority to the role of mobile communications in both developing and developed economies. The ITU has carefully planned for the evolution of 2G systems to 3G by specifying what it calls the “IMT-2000 technology family” to deliver 3G voice and enhanced data-enabled services. The industry has agreed and supports evolution paths from GSM and CDMA for their respective 3G technologies. The GSM operators, who today are serving over 1.43 billion users globally, are evolving to “WCDMA”, one of the official ITU/IMT-2000 3G radio access standards. CDMA operators broadly will evolve to “CDMA2000”, another of the official ITU/IMT-2000 3G radio access standards; however a number of CDMA operators have 2
  • 3. decided to abandon CDMA altogether and migrate to WCDMA (e.g. in Korea and the Americas). There are over 30 million UMTS/WCDMA subscribers globally, and this figure is growing rapidly. The latest survey by GSA (August 15, 2005) confirms that there are 82 WCDMA networks in commercial service in 37 countries (using IMT-2000 core band spectrum), and 186 WCDMA device models launched in the market by 26 suppliers. The superior spectral efficiency of the WCDMA technology will bring positive effects to the national economy. Furthermore, the opportunity to use HSPA (High Speed Packet Access), which is the first evolutionary step for WCDMA beginning in some markets from end 2005, can be the basis for national broadband coverage. C ITU 3G/IMT-2000 Spectrum Plan New spectrum has been identified by the ITU for 3G systems within which a “core band” for terrestrial services of 1920 – 1980 MHz paired with 2110 – 2170 MHz is allocated (i.e. 2 x 60 MHz). This band plan is adopted by virtually all countries of the world for the deployment of 3G/IMT-2000 systems, including throughout Asia and many countries in Latin America. The European Union has also adopted the ITU IMT-2000 frequency plan. Therefore any misalignment between the EU and Indonesia, and indeed other countries and Indonesia, would make communication more difficult and costly. This would in the longer term have an adverse effect for all parties, as people would not in the future be able to access their 3G services while roaming. Better communication will bring all countries closer together, and facilitate investment, which is why it is in everyone’s interest to adopt the same frequency allocation. The IMT-2000 technologies are designed to co-exist and to not interfere with each other. Designation of the “core band” ensures that manufacturers can produce equipment working in standard internationally agreed frequency bands to minimise complexity, and lower cost. For users, it guarantees the possibility of automatic international roaming, as enjoyed today by hundreds of millions of GSM subscribers. The convenience to GSM users of having one phone, one telephone number and one bill, and being able to make and receive calls not only on their home network but also in China, throughout Asia, Europe, Africa, the Americas, etc., indeed globally, must be guaranteed and preserved for future users of enhanced voice and data services delivered by 3G networks. D WLL/PCS 1900 Blocks Future Growth in IMT-2000 WLL services are currently delivered in Indonesia in the 1900 MHz band (the US PCS 1900 band plan) which overlaps the 3G/IMT-2000 core band as defined above. Continuing this service in the 1900 MHz band would block the evolution path for the GSM operators, who are supporting over 26 million customers (Q1 2005) in Indonesia, and who need to evolve quickly to WCDMA for voice capacity expansion and new revenue growth from enhanced data services. WLL employs 2G CDMA technology operating in the same band as WCDMA, which could not be operated in the same geographical area due to interference. This is a very serious issue and would be a major loss for Indonesian consumers and operators, severely upset economic development, investment and productivity, and cause a negative market impact over the next 10-15 years. Huge international roaming income would be at risk. No country in the world to our knowledge has deployed 2G systems e.g. WLL solutions at 1900 MHz alongside 3G/IMT-2000 systems. Furthermore, not only does the mixed allocation scenario not exist, but also countries that have considered such an arrangement previously including China and India, have abandoned this approach for the reasons explained in this response. The mixed band issue and related considerations and consequences are discussed in Annex 1 to this response "Approach to Frequency Spectrum Allocation." 3
  • 4. It is our understanding that DGPT appreciates the significance of the interference issues. Overcoming such interference if at all possible would require the establishment of "guard bands" between WLL/CDMA and 3G/IMT-2000 systems, resulting in large portions of the 3G band being unusable, and its value diminished. Furthermore, in addition to guard bands, some filtering would be needed, affecting the CAPEX of those operators who are allocated frequencies nearest the PCS1900 band. This leads to inequality between the licensees, and to complexity in the networks. In practice it may not be possible to completely mitigate against the interference issues. GSA's view is that allocating spectrum in the 1900 MHz band for anything other than 3G/IMT-2000 technologies must be avoided at any cost. Indonesia is ready for the next step of adopting 3G services. In line with the rest of the world, 3G evolution should occur in the IMT-2000 core band, so that Indonesia can benefit from the lowest cost systems and terminals, and thus the fastest and broadest service adoption can be reached. This will also ensure that Indonesia continues to be part of the global telecom evolution and is not left isolated. We trust that our comments will assist DGPT in its deliberations and policy decisions. In conclusion, GSA wishes to thank DGPT for the opportunity to review, discuss and respond to this consultation. We remain at your disposal to assist with answers to any questions you may have at this time, and to consider any requests for additional assistance, should this be required. Yours Sincerely, Alan Hadden President, GSA For and behalf of the Executive Committee Global mobile Suppliers Association www.gsacom.com 4
  • 5. Annex 1 Approach to Frequency Spectrum Allocation Introduction The objective of this paper is to bring forward the point that any allocation of PCS 1900 MHz frequency now will have a long-term negative impact on Indonesian telecom growth. 3G evolution is a market reality for 82 WCDMA operators in 37 countries The 3G evolution is a market reality for GSM operators across the world today. There are over 30 million UMTS/WCDMA subscribers globally, and this figure is growing rapidly. The latest survey by GSA (August 15, 2005) confirms that there are 82 WCDMA networks in commercial service in 37 countries (using IMT-2000 core band spectrum), and 186 WCDMA device models launched in the market by 26 suppliers. The logical evolution path to 3G for the GSM operators is WCDMA, deployed in the IMT-2000 core band. The benefits of 3G are obvious for both operators and consumers: • High voice quality drives usage and image - consumers enjoy good service • Very low cost of voice capacity – higher voice minute volumes at reduced costs • Higher data speeds for wireless broadband • Very low cost of data capacity - high-volume everyday data at affordable prices From 2005 onwards WCDMA operators can upgrade systems, with software only, to support HSDPA/HSUPA (High Speed Downlink/Uplink Packet Access). With these enhancements users can expect a true wireless broadband experience. In the first phase – the downlink direction, data speeds of 14.4 Mbps peak bit rates (typical user experience 1 – 4 Mbps) are expected to be achieved. To upgrade GSM networks to 3G, most of the existing network assets can be reused and only a small number of additional sites may need to be deployed to achieve a good coverage. Also, the WCDMA supply market operates at high volumes and is extremely competitive, enabling low deployment cost. Further, WCDMA improves spectral efficiency and reduces the cost of capacity for both voice and data. These three factors ensure that 3G/WCDMA presents a sound business case for the operators. Any PCS 1900 band allocation would destroy WCDMA evolution path Any allocation of PCS 1900 would block the WCDMA evolution path from GSM operators. This is because a cdma network in 1900 MHz band and a WCDMA network in IMT-2000 core band cannot be operated in the same geographical area, due to interference. If WLL/CDMA 1900 networks were maintained, the Indonesian GSM operators, and potentially new players, would not be able to deploy WCDMA networks. This would be a major loss for consumers and operators alike, and would cause a major negative market impact over the next 10-15 years. The interference issue cannot be mitigated against. The IMT-2000 core band uplink and the PCS 1900 band downlink are almost fully overlapping with each other (50 MHz out of 60 MHz), as shown in the chart below. The PCS-1900 allocation should be avoided at any cost. GSM 1800 Uplink GSM 1800 Downlink IMT-2000 Uplink IMT-2000 Downlink 75 MHz 75 MHz 60 MHz 60 MHz 1710 1785 1805 1880 1920 1980 2110 2170 1850 1910 1930 1990 1700 1800 1900 2000 2100 PCS-1900 Uplink PCS-1900 Downlink 60 MHz 60 MHz 5
  • 6. Co-existence of all IMT-2000 equipment inside the WARC-92 band plan (1920 – 1980 MHz paired with 2110 – 2170 MHz for terrestrial services) is supported by 3GPP/3GPP2 standards without any need for additional filters and/or site coordination. The specifications of terminals and network systems do not take into account the situation where 2G (e.g. WLL/cdma) and 3G technologies (e.g. WCDMA) would co-exist. As a result, two severe interference mechanisms arise: 1. Handsets interfering with each other • Single WCDMA terminal transmission can block all WLL/cdma1900 terminal receivers within the radius of up to 200 meters. • It is not possible to mitigate this mechanism, since the internal filters in terminals cannot reduce the interference as much as would be required. • Naturally, the consumers cannot be instructed to keep a certain minimum distance from other people who are talking to a mobile phone. 2. Networks interfering with each other Cdma base station transmission blocks the WCDMA base station receiver. This would require large guard bands, large-size filters, site co-ordination and increased base station density for all operators. In practice, however, the required solutions: • would be too complex to build and operate, • would pose severe limitations to potential site locations, • would roughly double the 3G coverage build costs for all operators. • would lead to large amount of waste spectrum because of guard bands • operators would not be able to execute this approach in a competitive environment. Inter-terminal Interference Evaluation in Mixed Band Environment The PSC1900 band terminal receiver (1930-1990 MHz) overlaps to a large extent with IMT-2000 core band terminal transmitter (1920-1980 MHz). The two kinds of terminals are not specified to operate in the same area. If they are implemented in the same area, severe interference mechanisms arise. • WCDMA terminal transmission blocks the cdma mobile receiver. • A single WCDMA terminal can seriously interfere with the reception of cdma 1900 terminals within a 200m radius of the WCDMA terminal. • It is obvious that cdma1900 and WCDMA2100 cannot operate in the same geographical area in a practical scenario The interference levels depend on the Rx-filters (receiver) of cdma and Tx-filters (Transmission) of WCDMA. The performance of WCDMA Tx-filters can be found in 3GPP specification 25.101. • Per specification, in the adjacent 5 MHz band (carrier) the attenuation must be 33 dB (on 5 MHz). • After the filtering for the adjacent 5 MHz, the attenuation is slower. In the following 5 MHz the attenuation must be 43 dB (i.e. 10dB more). • There is significant interference potential across the cdma receive band Calculation principles The severity of the interference depends on 3 things • The distance of the WCDMA mobile from the BTS (-> high Tx power) • The distance of the cdma mobile from the BTS (-> Rx-power low) • The distance between the two mobiles (-> Low attenuation) It is assumed that the WCDMA Tx-filtering is the limiting factor in interference estimations (I.e. it is more relaxed than the cdma rx-filter). 6
  • 7. • The maximum output power of a WCDMA mobile is 21 dBm (this is utilised at the cell edge). The new specifications will increase the power to 24 dBm, however this calculation assumes 21 dBm. • The path loss between two mobiles is given by the formula (assuming 0 dB antenna gains): path loss = 20*log10(distance in metres)+37 • The noise power is –105 dBm (law of nature) for cdma • It is assumed that downlink of cdma is destroyed if the interference of WCDMA is 10 dB above the noise power Calculation results The following results are available based on the mentioned assumptions: • The interference from a WCDMA mobile destroys the cdma downlink when the distance is 200m or less, assuming adjacent frequency deployment • The minimum distance reduces to ~100m, if 5 MHz guard band is assumed • It is possible that no amount of guard band can provide interference-free operation for mobiles which are close to each other, as the path loss for the two mobiles is very low. Based on the above it can be concluded that WCDMA and cdma 1900 cannot operate in the same area, in a practical scenario. Calculation formulas Below is a formula to calculate the minimum required path loss between the two mobiles: • pathloss_min = tx_power – filter_cdma_band - max_allowed_interference • The required distance in metres can then be calculated with the formula • distance_min = 10^[(pathloss_min-37)/20], • In other words, by combining the above formulas: • Distance_min = 10^[(tx_power – filter_cdma_band - max_allowed_interference – 37)/20] • The variables in the formulas are the following: • The value of filter_cdma_band is 43 if no guardband is assumed • The value of max_allowed_interference is –95 • The value of the tx_power is 21 All of the above variables are random variables with a distribution depending on many things, mainly the site density. Path loss (dB) as a function of distance (m) is shown in the following chart. • The interference potential between the two mobiles grows in a very rapid pace, as distance get smaller. • E.g. the path loss between the mobiles which are within 10m distance or less from each other is 20 dB smaller than path loss of mobiles within 100m from each other. This means that the interference signal level is 100 times larger in 10 meters distance compared to 100meters distance. • When two people speak next to each other, e.g. in an office or a public facility, the path loss is very small, and thus the level of interfering signal is very high. 90.0 85.0 80.0 75.0 70.0 Pathloss 65.0 Pathloss 60.0 55.0 50.0 45.0 40.0 0 50 100 150 200 250 300 350 Distance 7
  • 8. No country has deployed both PCS1900 and IMT-2000 core band systems Taking the above aspects into consideration, no country has in parallel deployed the cdma 1900 MHz and IMT-2000 core band systems in the same area. In China, there was a proposal to use the mixed plan, but the regulator realized that the negative factors, as explained in this response, outweighed any benefits, and decided to adopt the IMT-2000 plan. After extensive consultation and evaluation, the Indian Administration TRAI recently similarly rejected the “mixed band plan” approach. Japan already has commercial 3G/IMT-2000 services. Korea has allocated the IMT-2000 core band for both WCDMA and CDMA2000 3G services. It is very likely that China and Brazil will also do the same. Allocation of PCS1900 could lead to a waste of the full 60+60 MHz of commercially viable IMT-2000 core spectrum. Countries amounting to 90% of world population support IMT-2000 IMT-2000 is the global standard of the future, covering countries with 90% of the population. Several Mobile Service standards IMT2000 GDP U$ 19,7 trillions GDP 65 % of world U$ 9,3 trillions Pop 5,4 billion 31% of world 90% of World Pop 304 million 5% of World Mostly GSM-based evolution GDP U$ 1,2 trillions 4% of world Pop 317 million 5% of World As a consequence, IMT-2000 core band is a baseline requirement for GSM operators. 8
  • 9. Annex 2 QUESTIONNAIRE Directorate General Post and Telecommunication, Indonesia PUBLIC CONSULTATION ON THE RE-ARRANGEMENT OF THE FREQUENCY ALLOCATION FOR 3G/IMT-2000 SERVICES Background statement from DGPT (translated from the official consultation document) Currently the frequency allocation in the WARC-92 band (1920-1980 / 2110-2170 MHz) for terrestrial FDD is using Mixed Spectrum Allocation. It means that in this band, between 1920 and 1960 MHz was allocated for WCDMA using duplex pattern UMTS with duplex separation of 190 MHz. Between 1960 - 1980 MHz was allocated for CDMA2000 using duplex pattern PCS 1900 with duplex separation of 80 MHz. As a consequence, a guard band between these two formats allocation is needed and there is a duplex upper band that has no pair and cannot be used. This is a waste of spectrum and reduces the available spectrum for UMTS allocation. In avoiding or minimizing this without disturbing subscribers in the WRC-2000 band, there are several re-arrangement options. 1. The public is requested to provide a response or input on the advantage and disadvantage of the following options: a. All the allocation in the WARC-92 band uses duplex pattern UMTS independent of the technology options. List how many and which country adopt this alternative. Europe & most countries outside North America have adopted the WARC-92 bands to support first implementations for IMT-2000/3G services . There are over 30 million UMTS/WCDMA subscribers globally, and this figure is growing rapidly. The latest survey by GSA (August 15, 2005) confirms that there are 82 WCDMA networks in commercial service in 37 countries (using IMT-2000 core band spectrum), and 186 WCDMA device models launched in the market by 26 suppliers. Note also that CDMA2000, being also a member of the IMT-2000 radio access family (as is WCDMA) can be deployed according to the ITU core band plan, which is the situation in Japan and Korea. b. All the allocation in the WARC-92 band use duplex pattern PCS 1900 independent of the technology options. List how many and which country adopt this alternative We are not aware of any country which has adopted a mixed band plan (IMT-2000/US PCS 1900) approach. Allocation of the US PCS1900 band would mean denying the benefits of 3G/IMT-2000 services to consumers, enterprise and the national economy. c. As of current conditions, please describe how to get the arrangement that: (i) Can minimize spectrum wastage (ii) Can maximize the remaing spectrum that can be used for UMTS, and (iii) Without or minimum disturbance on the existing subscribers We strongly recommend and urge NOT to continue with a mixed band strategy. The ITU core band plan (1a) will ensure the optimal and most efficient spectrum allocation for 3G services in Indonesia. WLL customers can migrate to full mobility services enabled by GSM/3G according to market conditions. WLL could be replaced by building very cost-effective GSM networks. With the latest network solutions, it is possible to run a profitable operator business at ARPU levels of 3-5 USD. 9
  • 10. 2. What is the availability of the equipment that supports CDMA 2000 mode and duplex mode UMTS (as per definition of Band Class 6 according to 3GPP2) or vice versa, UMTS with duplex mode PCS 1900 (as Band Class 1 according to 3GPP2). The UMTS/PCS1900 duplex operation may be provided by future dual-mode terminals WCDMA1900/GSM1900, as GSM1900 operates in the PCS1900 band plan. No duplex operation with TDMA or CDMA is foreseen, although they are also covered by PCS1900. We are not aware of the commercial availability of dual-mode UMTS/CDMA2000 terminals, nor have the leading manufacturers announced firm plans to launch such products. We would add that due to the global commitment behind WCDMA, there are currently 186 WCDMA devices already announced in the market, which is a major contributor to the fast take-up of 3G services globally. 3. What is the impact on the alternatives 1.a - 1.c if the Government will keep consistent in implementation ITU R M. 1036-2. The mixed band plan 1c is not recommended in ITU-R Recommendation M.1036. ITU core band plan 1a, which is deployed in Europe and most countries outside North America, supports the first implementations for IMT-2000/3G services. There are over 30 million UMTS/WCDMA subscribers globally, and this figure is growing rapidly. The latest survey by GSA (August 15, 2005) confirms that there are 82 WCDMA networks in commercial service in 37 countries (using IMT-2000 core band spectrum), and 186 WCDMA device models launched in the market by 26 suppliers. Note also that CDMA2000, being also a member of the IMT-2000 radio access family (as is WCDMA) can be deployed according to the ITU core band plan, which is the situation in Japan and Korea. 4. As for licensing for the prospective operators in WARC-92 band that has no operating license yet, which way is better to grant the license; either via ”beauty contest”, ”Auction”, or the combination of both (hybrid). A hybrid solution potentially supports well the regulator and capable bidders: - if applicants are first evaluated in a beauty contest it gives the possibility for the regulator to identify those bidders who have realistic possibilities to build the networks. - Selected bidders should pay a reasonable fee for the licenses, which motivate them to actually build the network. The fee shall not be so high that it would jeopardize the actual investment in the infrastructure - a reasonable rollout plan should be required (but not necessarily stipulating a requirement for 100% coverage, and also phased over several years, if applicable, e.g. large cities first, then other areas according to the development needs in Indonesia) - If the rollout does not occur as required, the ultimate penalty should be withdrawal of the license A hybrid solution appears to be a valid option to ensure that the infrastructure is built. There are examples in the world which show that where concrete obligations to build 3G network coverage apply, those countries have a good 3G coverage today (e.g. Sweden, Austria). 10
  • 11. If a “beauty contest” is used, then rollout obligations should be tight, even providing for taking back the license if rollout obligations are not fulfilled. However, in a beauty contest without a fee, there is no motivation or real financial risk for the bidder. If an auction is used, the winning bidders normally have more freedom in rollout, making it more difficult to evaluate the applicants' capabilities to build the network. The price paid in an auction might also jeopardize the bidders financial position to be able to invest in the actual infrastructure. 5. Should TDD spectrum allocation (1900-1920 and 2010-2025 MHz) be tendered separately or should it be considered in the same package with FDD (1920-1980/2110-2170 MHz) tender? TDD has been considered as potentially a part of the 3G services delivery option for certain market segments, and some equipment vendors are trialling initial products and solutions. As such TDD can be considered in the same package as FDD, or separate according to market interest. However at this time TDD is only at pre- commercial stage. The clear majority of product offering in the market today is FDD, where WCDMA leads the market. There are over 30 million UMTS/WCDMA subscribers globally, and this figure is growing rapidly. The latest survey by GSA (August 15, 2005) confirms that there are 82 WCDMA networks in commercial service in 37 countries (using IMT-2000 core band spectrum), and 186 WCDMA device models launched in the market by 26 suppliers. 6. In your opinion, how big is the optimal bandwidth requirement (2 x 5MHz or it’s multiple) that is required for each operator to deploy 3G services nationwide? Mobile operators need certainty on the amount and quality of new spectrum they will have on which to base and build their businesses. The UMTS Forum studied the issue of minimum frequency band per UMTS operator (UMTS Forum Report No. 5 – published 1998) and recommended 2 x 15 MHz per operator as the preferred minimum in the initial phase. This advice has been followed in several countries. 7. In considering point no. 6, should the new license allow or oblige in-country roaming between 3G to 3G operators or 3G to 2G operators? at least during the development phase. National roaming has proven to assist new players coming into the market. The interconnection arrangement needs to strike a balance between extending competition, and not discouraging network investments by incumbents. 8. The usage efficiency of this highly valuable 3G spectrum will be very bad if the winner of the tender, due to lack of funds or other reasons, cannot roll out the network in the committed timframe. What is the best rule for the the roll-out obigation and what penalties should be applied in case the target can not be fulfilled? See response to Question 4 above 9. Should this 3G spectrum (2 GHz band) re-arrangement plan necessarily be linked with the spectrum allocation in 800 MHz? Spectrum allocations are inter-related and should be made independant of technology. It is important not to risk distorting the market which would follow if frequencies were allocated which favored a specific technology while excluding competitive use of other technologies. 11