NHS Information Authority,
Public Wireless Networks Unit
Radiocommunications Agency 24th July 2003
11R/2A Wyndham House
189 Marsh Lane
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
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
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.
Mobile Communications & Ambulance Support Manager
NHS Information Authority
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?
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?
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
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.
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
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
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.
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
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
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