Ref: Consultation on the Telecommunications Radio Frequency Spectrum in the Kingdom of Bahrain. WiMAX Forum Response

Transcription

1 10 February 2010 For more information, contact: Chair, Regulatory Working Group To: The General Director Telecommunications Regulatory Authority B.O. Box 10353, Manama, Kingdom of Bahrain Ref: Consultation on the Telecommunications Radio Frequency Spectrum in the Kingdom of Bahrain WiMAX Forum Response The WiMAX Forum welcomes the opportunity to provide its views and comments concerning the issues raised in the public consultation document on the topic above. The WiMAX Forum,1 is an industry-led, not-for-profit organisation formed to certify and promote the compatibility and interoperability of broadband wireless products based upon the harmonized IEEE /ETSI HiperMAN specifications. A WiMAX Forum goal is to accelerate the introduction of these systems into the marketplace. WiMAX Forum Certified products are interoperable and support Metropolitan Broadband Fixed, Nomadic and Mobile Applications. Along these lines, the WiMAX Forum works closely with service providers and regulators to ensure that WiMAX Forum Certified systems meet customer and government requirements. For more information about the WiMAX Forum and its activities, please visit The WiMAX Forum responses to this consultation can be seen in Annex 1. Yours Sincerely, Tim Hewitt WiMAX Forum Director of Spectrum Policy and Regulation Chair - Regulatory Working Group 1 WiMAX, Mobile WiMAX, Fixed WiMAX, WiMAX Forum, the WiMAX Forum logo, "WiMAX Forum Certified, and the WiMAX Forum Certified logo are trademarks of the WiMAX Forum.

2 Annex 1 WiMAX Forum response to the TRA call for comments on the: Consultation for The Telecommunications Radio Frequency Spectrum in the Kingdom of Bahrain Introduction The WiMAX Forum welcomes the opportunity to provide its views to TRA. We believe this consultation will be an important catalyst for a thriving broadband wireless access environment in Bahrain. The WiMAX Forum appreciates TRA for the introduction of WiMAX services at 3.5 GHz band in Bahrain and we hope it will continue with the licensing 2.3 GHz and 2.6 GHz bands.. In the last decade telecommunication capabilities and subscriber usage have changed dramatically. This is especially valid for mobile and Internet based services. Along with the strong increased usage of mobile and IP based services, the dependency of individuals, corporations and entire economies on the availability of respective telecommunication networks has increased dramatically. In addition to basic voice connectivity, broadband data services can play a key roll in economic development in both developed and emerging markets. This information technology revolution is available only for those who have affordable access to these broadband networks. The WiMAX Forum s objective is to foster broadband connectivity anytime and anywhere. Before WiMAX Forum Certified systems were available, many solutions were custom-built and non- interoperable. Every piece of WiMAX Forum Certified equipment based on a common profile is interoperable with other WiMAX Forum Certified equipment. WiMAX Forum Certified means a service provider can buy equipment from more than one company and be confident everything works together. WiMAX Forum Certified means a more competitive industry, lower costs, and faster growth for broadband wireless everywhere around the globe. WiMAX is the first all IP and OFDMA based IMT-2000 standard. The OFDMA technology has become commonly accepted as the basis for the evolution of mobile technology towards 4G, as it can provide high data rate capability and excellent support for new features such as advanced antenna technologies to maximize coverage and the number of users supported by the network. OFDMA (specifically, the air interface designated WirelessMAN-OFDMA within IEEE ) provides multipath and interference tolerance in non-line of sight (non-los) conditions to achieve ubiquitous broadband coverage in a wide range of operating environments and usage models, including full mobility. Currently, there are 190 WiMAX Forum Certified products and many products are entering the certification process. The WiMAX Forum estimates that by 2011 there will be more than 1,000 Mobile WiMAX Forum Certified products found throughout the world. WiMAX Forum response to Bahrain TRA, Radio Spectrum Consultation February

3 Responses to Consultancy Questions Consultation Question 1 TRA is of the view that the current framework for spectrum management will be found inadequate with respect to proactively identifying the future demand for radio frequency spectrum. In defining a new framework and spectrum release plan TRA intends to take into account: the future shape of radiocommunications; international developments; the encouragement of investment; strategic considerations; fair compensation for the community; and the avoidance of hoarding spectrum. TRA invites comment with respect to the factors to be considered in designing a Spectrum Release Plan for the Kingdom of Bahrain. Response 1 The WiMAX Forum supports the TRA s work to define a new framework and spectrum release plan. Radio spectrum is a scarce resource and efficient usage of spectrum and management is very important for the introduction of next generation wireless broadband services. Next generation wireless broadband technologies provide higher data rates and affordable broadband services for users. New wireless broadband technologies (such as WiMAX, LTE) need more spectrum for the introduction of next generation wireless broadband services. And this need will continue to increase with the introduction of IMT-Advanced services. The WiMAX Forum supports the assignment of spectrum in a technology and service neutral manner. Consultation Question 2 TRA is minded to revise and modify the Generic Frequency Licence, as well as removing and relocating licences terms and conditions to TRA s web-site, rather than maintaining them in a hard-copy format, attached to each and every licence. The licence s terms and conditions would be incorporated by Regulation into the Generic Frequency Licence. Both the draft future Generic Frequency Licence and the draft terms and conditions text are attached in Annex 2. TRA therefore invites comments on the proposed text modifications in Annex 2 and the intention of locating the licensing conditions on the TRA web site. Response 2 The WiMAX Forum has no any comment. WiMAX Forum response to Bahrain TRA, Radio Spectrum Consultation February

4 Consultation Question 3 TRA plans to introduce a minimum notice period if frequency assignments are subject to modification or withdrawal. What are your suggestions with respect to an appropriate minimum notice period? Response 3 The WiMAX Forum agrees with the application of minimum notice period. Consultation Question 4 In addition to the current migration policy in Regulation No. 3 of 2008 and in co-operation with the SSCC should a policy on spectrum refarming and spectrum migration be evolved, which will establish policy and compensation procedures for all spectrum users in the Kingdom? Response 4 The WiMAX Forum has no comment. Consultation Question 5 Whilst TRA is of the opinion that TDF is the most expedient form of refarming compensation mechanism it recognizes the deficiencies of the approach with respect to users not subject to the Telecommunications Law, since such users would also be not subject to Regulation No. 3 of TRA invites comments on how best to incorporate such users into a refarming compensation scheme and the appropriate minimum notice period(s) to be applied to refarming. Response 5 To benefit from the experiences of other countries can be useful. Consultation Question 6 TRA is of the opinion that there should be no legitimate expectation of licence renewal on expiry of a spectrum assignment provided that sufficient notice of the intentions of TRA is provided. TRA invites comments on the concept of no automatic or legitimate expectation for spectrum assignment renewal as well as views concerning an appropriate period of notice prior to the expiry of a service licence with associated spectrum assignments. Response 6 WiMAX Forum response to Bahrain TRA, Radio Spectrum Consultation February

5 The WiMAX Forum believes license duration should be sufficient to enable investment opportunities which will enable further development of mobile broadband services. We also recommend the inclusion of license renewal rights. Consultation Question 7 TRA invites comment on the potential licensing and use of the bands MHz and MHz for public (commercial) mobile services in the bands MHz or MHz? Response 7 The WiMAX Forum recommends the assignment of spectrum band in a technology neutral manner; In accordance with ITU-R Resolutions 224 and 646. Consultation Question 8 TRA invites comments on the potential designation of all or parts of the band MHz for ITU designated IMT services? Response 8 The WiMAX Forum recommends the assignment of the spectrum band in a technology neutral manner; In accordance with ITU-R Resolutions 224 and 646. Consultation Question 9 TRA is of the opinion that proposals for a license in the bands MHz and MHz should be abandoned in view of digital dividend studies, SRD developments and a possible GSM-R requirement. TRA invites comments on the future uses of these bands. Response MHz band has been identified by ITU for IMT applications in Regions 1 and 3. Therefore, this band is very important for mobile services. The WiMAX Forum also recommends the flexibility in spectrum usage and market based flexible TDD/FDD splitting for 800 MHz band. Consultation Question 10 TRA invites comments on the potential future uses of spectrum bands currently used for FWA systems in the Kingdom, in particular should spectrum at 10 GHz, 26 GHz, 28 GHz and 40 GHz be maintained for FWA licences or should it be considered for alternative WiMAX Forum response to Bahrain TRA, Radio Spectrum Consultation February

6 applications, which are in accordance with the NFP? Response 10 The WiMAX Forum has no comment. Consultation Question 11 TRA invites comments relating to any other of the data provided in Table 1 and Table 2? Response GHz band has been identified by ITU for IMT services. The WiMAX Forum supports the European Commission s Decision 2008/411/EC and CEPT s Decision ECC/DEC/(07)02 in the 3.4 to 3.8 GHz band. These decisions provide flexibility to administrations for the mobile service application at 3.5 GHz band. Consultation Question 12 TRA consider it appropriate to publish a non-binding Telecommunications Spectrum Release Plan (TSRP) covering spectrum suitable for all sectors managed by the TRA. TRA invite comments on the proposed TSRP contents and review period. Response 12 The WiMAX Forum supports the proposal of TRA. Telecommunications Spectrum Release Plan will be useful. Annually review of Consultation Question 13 TRA invites comments on its proposal, subject to SSCC approval, to: Offer amateur licensees in the Kingdom additional spectrum at 500 khz, 5.3 MHz and 70 MHz in order to participate in propagation experiments. Introduce a band at MHz paired with MHz for private maritime applications. Seek to introduce a lightly licensed short range communications system based on internationally available hand-held equipment, ideally at 446 MHz. Reserve the GSM-R frequency bands at 900 MHz for possible use in relation to the GCC railway project and review the situation in Determine whether spectrum gained as a result of the transition from analogue to digital terrestrial television should be used for broadcasting, fixed, mobile (IMT), converged services or other applications. Response 13 WiMAX Forum response to Bahrain TRA, Radio Spectrum Consultation February

7 The WiMAX Forum supports technology and service neutral assignment of spectrum bands in harmonized manner with ITU decisions. We also recommend the usage of technology neutrality in table-3, instead of referring to only a specific technology, LTE MHz band has been identified by ITU for IMT applications. Therefore, we recommend the usage of spectrum gained as a result of the transition from analogue to digital terrestrial television be used for mobile services (e.g. WiMAX, LTE etc.). WiMAX Forum s candidate profiles includes MHz band and certified products will be available in this band. Consultation Question 14 There remain concerns about PMR446 (or similar equipment) being used for antisocial or illegal activities, TRA invites comments on how these may be overcome. Response 14 The WiMAX Forum has no any comment. Consultation Question 15 TRA invites comments on the consideration that services currently operating at 2.3 GHz and 2.6 GHz might be refarmed to provide additional spectrum for IMT systems. Response 15 The frequency bands MHZ and MHz were identified in the course of the WRC 2000 and WRC 2007 for IMT-2000 systems. 2.3 GHz and 2.6 GHz spectrum bands are key global band for next generation mobile broadband services and WiMAX Forum certified products are available from many member companies. Mobile WiMAX will become a standard feature in MIDs (Mobile Internet Devices), laptops, netbooks and other mobile devices. According to ITU statistics, Broadband penetration rate in Bahrain is 14.18%, Mobile penetration is % whereas mobile networks cover 100% of the population. It is understood that this coverage does not support broadband services and the existing mobile networks do not meet the broadband and internet aspirations of Bahrain citizens. Bahrain can economically and rapidly increase the broadband and internet penetration rates by transforming the existing mobile users to next generation mobile broadband users. This transformation requires the licensing of 2.3 and/or 2.6 GHz spectrum bands and to achieve the maximum benefit from WiMAX. Consultation Question 16 TRA invites comments on its proposal to provide the band GHz for short range and fixed wireless systems within the current light licensing regime. Response 16 The WiMAX Forum has no any comment. Consultation Question 17 WiMAX Forum response to Bahrain TRA, Radio Spectrum Consultation February

8 TRA invites comments on its proposal to make available the band GHz for fixed wireless systems using a modified light licensing regime, as described above. Response 17 The WiMAX Forum has no any comment. Consultancy Question 18 Do you have any proposals for additional frequency bands or telecommunications applications? Please note. All proposals should include the following information: The proposed frequency band(s); The bandwidth required; Details of the service(s) which could be provided in the proposed frequency bands; The proposed number of licences; The proposed licensing mechanism; and Any other comments or suggestions. Response 18 The proposed frequency bands; The WiMAX Forum recommends the acceleration of licensing at 2.3 GHz and/or 2.6 GHz bands for the introduction of next generation mobile broadband services in Bahrain. Bandwidth Required; The economic viability of a service provider s business case is highly sensitive to the size of the spectrum allocation license. Spectrum available for deployment determines base station capacity. Capacity constraints impair an operator s ability to create a compelling business case by: - Affecting the breadth of services and QoS that can be offered - Increasing capital and operating expenses - Affecting affordability of broadband service prices In order to deliver a truly valuable personal next generation mobile broadband experience, the WiMAX Forum recommends that operators (national) should be provided with a minimum of 30 MHz (excluding guard bands) contiguous unpaired spectrum in the 2.3 GHz and/or 2.6 GHz bands. More spectrum would provide a greater opportunity to successfully deploy at the national level. The amount of spectrum per operator should be sufficient to enable them to deploy a true mobile broadband system that is then capable of competing with and complimenting other wired broadband services. The amount of spectrum should be such that it would allow an operator to choose wide channels, e.g. 10 MHz and be able to choose a low risk frequency reuse plan, e.g. 3:1. Therefore as WiMAX Forum response to Bahrain TRA, Radio Spectrum Consultation February

9 mentioned previously, a minimum allocation of 30 MHz per operator would allow a positive business case to be developed. Operators should be able to increase the amount of spectrum in future according to their need for the introduction of IMT-Advanced services (for example, IEEE m will use increased channel widths as stated above). IMT-Advanced networks will use wider channels (20 MHz or higher) and operators will need more spectrum band in future, therefore the flexibility of TDD operation and efficient usage of spectrum are also very important for the evolution towards IMT-Advanced services in Bahrain, such as IEEE m. Details of the service(s) which could be provided in the proposed frequency bands; In parallel to convergence of mobile and fixed networks new standards and products supports fixed, nomadic and mobile service applications over same network. WiMAX products also supports fixed, nomadic and mobile applications. The WiMAX Forum recommends the allowance of fixed, nomadic and mobile services without any limitation. License Duration; The WiMAX Forum believes license duration should be sufficient to enable investment opportunities which will enable further development of mobile broadband services. We also recommend the inclusion of license renewal rights. WiMAX Forum response to Bahrain TRA, Radio Spectrum Consultation February