Spectrum

Spectrum Commons Classes for Licence-Exemption

Issued July 10, 2008

Introduction

BT is pleased to respond to this consultation on the management of spectrum used by licence-exempt devices and we appreciate Ofcom’s effort to tackle this technically complicated subject.

BT agrees with the general approach that Ofcom is taking, notably the principles of spectrum commons classes based on interference characteristics and the proposition of politeness rules. We also note favorably that there is no intention to apply the proposed methodology to the existing licence-exempt bands.

We agree that an early discussion of the future approach to licence-exempt spectrum management is appropriate, not least because there is a need to consider harmonisation of new licence-exempt spectrum bands considering the intrinsic mobility of many licence exempt devices as well as the social and economic benefits of a European (or International) wide market. For this reason BT supports Ofcom’s intention to align with the European work on Collective Use of Spectrum.

BT does have some concerns on some aspects of the consultation document. We understand that Ofcom proposes a general approach intended to cover a large range of frequencies and technologies, many of them still unexplored. As a consequence, there is an inherent contradiction between to need to be as generic as possible and, on the other hand, to detail how the methodology applies to a specific frequency bands and/or application. Also, although a very good general framework is being proposed, BT feels that the required details for the development of unambiguous regulations for licence exempt bands is missing. Furthermore, in addition to the proposed classification, efficient sharing in a certain frequency band is likely to require comprehensive compatibility studies for which specific assumptions on the equipment and application characteristics will be needed.

BT has doubts with regards to the definition and practical implementation of some of the concepts and parameters in the consultation document and these are detailed in the answers to the questions raised by Ofcom that we provide in Section 2.

Download the full response as a PDF document

BT welcomes comments on the content of this document. Comments should be addressed by e-mail to chris.cheeseman@bt.com.