Digital Dividend review

Digital Dividend review: 550-630 MHz and 790-854 MHz - consultation on detailed award design

Issued August 13, 2008

Executive Summary

1 BT is generally supportive of the approach that Ofcom is taking in relation to the award of the cleared DDR spectrum. However, we have concerns on a number of areas of detail, particularly in relation to certain technical aspects and in relation to how the spectrum will support competitive provision of mobile broadband services.

2 We understand why Ofcom proposes to include channels 61 and 62 as part of the cleared award. However we are unclear as to what limitations the concurrent TV use of these channels will place on the utility of these channels for other services. The continuing TV use of these channels and the proposed use of channel 69 for PMSE applications together serve to reduce the alignment of the cleared spectrum in the UK with respect to the global IMT band of 790-862 MHz, which is also emerging as a non-mandatory harmonized European mobile band for which mobile systems are being standardized. We therefore urge Ofcom to consider this situation carefully to ensure there is as much clarity as possible on the utility of the 790 – 862 MHz band and that particular concerns in relation to the limited amount of harmonized mobile spectrum are addressed.

3 We also have a number of concerns on details in relation to the proposed Technical Licence Conditions (TLCs), including guard band requirements, as well as concern with the proposed licence condition requiring protection of DTT receivers because the practical implications of this condition are rather unclear to us at present.

4 On the timing and details of the proposed auction method and how it may operate we have provided our views to the extent possible given the outstanding uncertainties on technical and other aspects. We note that further detailed consultations are expected to follow on these matters and we may therefore provide additional views in due course.

5 BT remains ready to work with Ofcom and other stakeholders in the further design of this important spectrum award, to address the matters raised in our responses to the detailed questions as well as the ongoing related international work.

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BT welcomes comments on the content of this document. Comments should be addressed by email to lorraine.flawn@bt.com.