Technical Requirements for Short Range, High Data Rate Equipment operating in the frequency range 5150 to 5875 MHz - Final Stage

BT response to the Radiocommunications Agency's Consultation on proposals for Technical Requirements for Short Range, High Data Rate Equipment operating in the frequency range 5150 to 5875 MHz - Final Stage

Executive Summary

1. BT welcomes this opportunity to contribute to the development of new regulation for the 5GHz bands. We believe this present consultation to be an important element of the broader consultation process now underway that will hopefully realise the full economic and social benefits that licence-exempt spectrum can provide.
2. In that this consultation proposes that access to the 5GHz bands is broadened to allow public tetherless access applications, it is welcomed by BT. In conjunction with similar treatment of the 2.4GHz band this will allow a significant step forward in achieving a Broadband Britain. Whilst the tetherless market is initially to be found in 2.4GHz, we believe the 5GHz bands will provide space for market growth, higher data rates and innovation in technology and applications.
3. BT was pleased to find that the Radiocommunications Agency had accepted the general principles behind the Recommendations of the UK 5GHz Advisory Group. We believe that operators, manufacturers and potential new players in the licence-exempt bands all supported these recommendations.
4. The close alignment between the 5GHz Advisory Groups output and RAs own proposals in this present consultation means that BTs position, as set out in this document, is generally supportive of the Radiocommunications Agencys proposals for 5GHz regulation.
5. Notwithstanding our general support, we have found it necessary to highlight a few significant concerns relating to the implementation of the new regulation that we believe need to be addressed before the 5GHz regulation would be successful in stimulating a dynamic 5GHz licence-exempt environment. These concerns relate to terminology, detail of the regulatory proposals and the relationship between UK regulation and the ERC Decision on 5GHz spectrum.
6. BT is particularly concerned over aspects of the regulation relating to the use of Dynamic Frequency Selection (DFS). We believe the complexity of the DFS issue, including the lack of an agreed requirement for its functionality, is a risk to the early development of Technology for the UK/European 5GHz market.
7. BT considers that, by mandating a complex DFS requirement for a limited market (because of varying national frequency arrangements, policy and timescales for licence-exempt bands), the present ERC Decision could inhibit or delay a truly competitive market for 5GHz devices. We believe that the UK should show leadership in developing a flexible, phased, approach to achieving the full implementation of DFS as required by the ERC Decision. BT offers some ideas for consideration by the Radiocommunications Agency.
8. BT has identified a range of issues associated with the draft Interface Requirement that accompanied the consultation document. It appears that further attention will be needed to the logical coupling of the requirements of ERC Decision (99)23, the final drafting of the relevant ETSI standards and the UKs own regulatory text.

BT would welcome further discussion on the contents of this paper with interested parties. In the first instance comments, questions, requests for further details or points of clarification should be addressed to:

Miss Lorraine Flawn
Senior Regulatory Adviser
pp 4TH FLR
Dowgate Hill House
14-16 Dowgate Hill
London
EC4R 2SU
Tel 020 7728 4189
Email: lorraine.flawn@bt.com