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NHS Information Authority


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NHS Information Authority

  1. 1. NHS Information Authority, Primrose Lane Huntingdon Cambs. PE29 1WG Martin Fenton, Public Wireless Networks Unit Radiocommunications Agency 24th July 2003 11R/2A Wyndham House 189 Marsh Lane London E14 9SX Dear Mr. Fenton, Consultation on the use of the 1781.7-1785 paired frequency bands for the provision of GSM 1800 services. The NHS Information Authority welcomes the opportunity to participate in the consultation process regarding the future use of these bands. The NHS Information Authority is established as a Special Health Authority with the remit to: “Improve patient care and achieve best value for money (VFM) by working with NHS professionals, suppliers and academics and others to provide national products, services and standards, which support the sharing and most efficient and effective use of information.” Your consultation document is proving a catalyst for ideas on improved communication within NHS establishments. In particular we are drawn to the concept of a low-power, on-site “cordless-telephone” using GSM technology with the ability to provide paging services using the associated SDS service. Many NHS hospitals are currently using ageing analogue pager technology to doctors and other clinical staff both routinely and in emergencies. These systems will need to be replaced in the near future. The fact that the same device can be used for two-way voice communication, although not a new concept, is also an attraction in that the use of GSM technology should drive down costs and consequently increase usage to the point where the “cordless hospital” can become a reality. The potential ability to use the same device on public services in its conventional, wide area GSM role offers much more freedom to the hospital user and potentially extends the client base to include those staff who are based in hospitals and yet spend much of their working day with patients in the community. There are, of course, a number of caveats such as security, confidentiality, interference with medical equipment etc but we see this concept as a very attractive solution. I attach responses to the questions raised in your consultation document but I should stress that our responses are largely centred on this particular concept. We look forward to seeing the results of your deliberations but, in the meantime, if you have further queries, please feel free to contact me. Yours sincerely, Mike Sprague Mobile Communications & Ambulance Support Manager NHS Information Authority
  2. 2. 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? No. Whilst cell-splitting and other techniques are a relatively expensive option for expansion of GSM services, this has to be set against the background of current and future financial returns. The regulator has recently commented on the high profit levels achieved by GSM operators and it would seem more appropriate to examine other new applications for which spectrum limitations have proved a major development or growth inhibitor. 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? N/A 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? N/A 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? Our concept, outlined above in the covering note, would rely on short range, low-power GSM technology. This could overcome or minimise the risks of interference with sensitive medical equipment within the confines of a hospital site. However, we do have serious concerns for this application regarding de-regulated spectrum. The primary concern relates to security. Inevitably, in a hospital environment, patient identifiable information could, despite the best intentions of the user, be transmitted over the network. The NHS has a duty to protect such information whether in spoken word or electronic data format, and the risks of interception by non-authorised users (either deliberate or casual eavesdropping) would be that much greater in a de-regulated environment. It would equally be intolerable if, for any reason, members of the public could access the on-site hospital “cordless paging/phone” network and thereby potentially obtain access to the PSTN though the PBX. 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. The concept of combining a wide area GSM service with an on-site, low-power GSM “cordless telephone/paging” service is described in our covering note. The NHS has more than 400 large such sites in England. The market size would include hospital staff particularly for the on-site phone and paging services but also the increasing number of community staff (district nurses, midwives, community nurses etc) who are based in local hospitals but spend much of their working day in the community, would benefit from both on-site and wide area services.
  3. 3. Penetration is difficult to estimate at this concept stage without information on prices of the on-site facilities and adapted phones. On the basis that the technology is well known and mass-produced, we would assumed that the unit costs would be low and comparable with conventional GSM phones. On this basis we could envisage significant penetration resulting in some 100-500 thousand users in England. Question 6 If your answer to question 4 is yes, should the use of this spectrum for the provision of public services be allowed? No, principally for the security reasons outlined above. The concept is more akin to a PBR radio/paging service. 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. N/A 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 No. There is already significant spectrum allocated for 3G purposes with the roll-out and take up as yet very uncertain. The question presumably arises because this spectrum is already allocated to the licensed service providers themselves and it will be manufacturers who will be seeking spectrum for T&D work. Whilst this is understandable, we believe manufacturers would only need the spectrum in a limited geographical area and then probably for limited periods of the day. It seems inappropriate to allocate national spectrum for this purpose. We do not understand why SP’s should be seeking additional spectrum to assist in the migration to 3G services. This would seem to create a defacto use of this spectrum for ongoing 3G services (beyond migration) and our views on this are similar to GSM public use of this band outlined above (Q1). 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? No. Migration to 3G services should be best managed by the SP’s themselves within the spectrum already allocated. We all recognise that spectrum is a scarce resource and, whilst 3G offers exiting prospects for future services, the development of other applications, such as the concept described above, should not be constrained by lack of spectrum. Question 10 If your answer to question 9 is yes, what period do you consider is appropriate? N/A
  4. 4. 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? We would have concerns if the spectrum was allocated on a technology neutral, licence exempt basis. The anticipated transmissions would include urgent calls to Doctors or emergency staff and the risks of other technologies in neighbouring areas causing interference to the network could prove excessive.