GSA response to the Ofcom call for input “3.8 GHz to 4.2 GHz band: Opportunities for Innovation”

The GSA Spectrum Group (GSG) 1 welcomes the opportunity to respond to this Ofcom call for input.

The GSG considers the band 3400-4200 MHz to be a key element in the development of 5G, and for the support of wide coverage enhanced Mobile Broadband, massive machine connectivity and critical and real time communications for high reliability or extremely low latency applications.

The GSG considers the availability of 400 MHz of additional spectrum adjacent to the band 3400-3800 MHz to be an important element for the establishment of the highest performing 5G networks globally, both in terms of the development of a vibrant device eco-system, and in terms of facilitating the evolution of mobile networks from existing 4G technologies to new air interfaces, with the possibility of making this available to UK citizens cost effectively. The GSG supports the following principles:

  • We consider that licensed spectrum is essential for mobile networks in order to allow the quality of service to be managed effectively and in a spectrally efficient manner. We are encouraged by Ofcom’s approach regarding licensed use of 3800-4200 MHz in the proposed “TIer-2”. We consider that such “Tier-2” use should be based on national licences rather than geographic licences.
  • We consider that a two-tier sharing framework – between Tier-1 incumbents and Tier-2 new licensees – should correspond to least restrictive technical licence conditions which avoid over-cautious assumptions on the risk of harmful interference. We consider that this is essential to allow the efficient sharing of spectrum, and to realise the full value of the 3800-4200 MHz band through national Tier-1 licenses. We believe that such two-tier spectrum access scheme should be based on the established Licensed Shared Access framework and should work on its possible improvements (e.g. accounting for the specificities of the 3800-4200 MHz incumbent users)
  • We consider that the inclusion of a third tier for opportunistic use of spectrum would make the framework over-complex, increase the risk of substantive interference to tiers 1 and 2 (which will include mobile victims), and result in inevitably restrictive conditions for Tier-3. We encourage Ofcom to consider a two-tier framework in the first instance, and to consider a third tier only when Tier-2 licensed use of 3800-4200 MHz has been well established.
  • We consider that technology and service neutrality are important cornerstones of progressive spectrum regulation; the market is best placed to decide on the most appropriate technology and service. As such, we consider that the band 3400-4200 MHz should be available for use by all 5G applications, including large-cell and small-cell network deployments, and subject to least restrictive technical conditions. We consider that access to 3800-4200 MHz for 5G would bring significant benefits to UK citizens and consumers, by allowing a wide range of services and applications as we move forward towards a new era in mobile communication.

1 The Global mobile Suppliers Association (GSA) represents mobile suppliers worldwide, engaged in infrastructure, spectrum, semiconductors, devices, services and applications development, and support services. The GSA Spectrum Group (GSG) develops strategies and plans, and contributes studies and technical analysis to international, regional and individual country policy-makers and regulators to facilitate the timely availability of spectrum for use by mobile network operators. GSG is the GSA focus group for technical and regulatory matters of radio spectrum pertaining to the successful evolution of International Mobile Telecommunication (IMT) and associated radiocommunication systems and comprises a team made up of spectrum and regulatory affairs specialists from GSA Executive Member and GSA Member companies. The GSG is participating in the study work leading up the World Radiocommunications Conference meeting in 2019 (WRC-19). In addition GSA reports regularly on global spectrum harmonisation efforts and developments including auctions, assignments, allocations, and re-farming activities

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