Spectrum

Spectrum Usage Rights

Issued 8 February, 2008

Introduction

BT has examined this further Ofcom consultation on Spectrum Usage Rights (SURs). This latest document comes very soon after Ofcom’s statement on this topic and we note that it introduces significant new technical aspects. These are extremely complex in their nature, particularly in the detail of how the latest concepts would be implemented in a practical sense. The proposals require more time than Ofcom has allowed in order for them to be analysed thoroughly. Within the 4 weeks that Ofcom has set for this consultation it has proven to be difficult to fully comprehend and evaluate all of the new proposals that are made. BT has therefore provided in this response an initial assessment of Ofcom’s proposals and we may make further representations, if necessary, after further engineering analysis.

BT has supported the basic principles and aims of the SUR concept, but we continue to believe that there is a good deal more work to be done before these new ideas contained in this latest document would be mature enough to be used in a practical, commercial environment and suitable for inclusion in spectrum awards. We note that SURs could always be introduced at a later stage in bands where they are not included at the time of the initial award and therefore further work to improve the SUR proposals need not affect the timing of the awards schedule. Furthermore, we note the good progress within Europe on WAPECS and the block edge mask concept for spectrum licensing, which arguably satisfies some of the objectives of SURs in terms of facilitating greater technology neutrality.

You can download the full response as a PDF document

BT would welcome any comments on the contents of this document. Comments should be emailedto Chris Cheeseman.