Response to Ofcom’s Call for Inputs on Opportunities for Innovation in 3.8GHz – 4.2 GHz UK Broadband Limited and UKB Networks Limited (together “UKB”) are backed by the PCCW / HKT group in Hong Kong and work together in the UK to provide fibre and wireless networks and services to businesses and consumers, under the brand name Relish. We welcome the opportunity to comment on Ofcom’s initial views with respect to the possibilities for sharing and innovation in the 3.8 GHz – 4.2 GHz band. UKB’s current and planned usage in the band UKB has 84 MHz of spectrum in this band at 3925 – 4009 MHz. We currently have three principle uses for the spectrum: i) Point to Multi-Point Through our consumer brand, Relish1, we provide business customers with a Dedicated Business Internet (“DBI”) service (akin to a “leased line” service) using Point to Multi-Point technology. Our frequency allocation means that we can utilise an 80 MHz channel to provide high bandwidth services. [] ii) Point to Point Relish uses Point to Point technology in 3.9 GHz to provider higher bandwidth DBI services. With technological advances, throughputs of up to 100 Mbps can be achieved in this band2. iii) Fixed Links for Backhaul UKB also uses 3.9 GHz for fixed links to deliver backhaul for its own micro-cells, particularly in areas of low population density. We use a meshed system to connect base stations and micro-cells to fill gaps in our LTE network. UKB forecasts that it will require use of its 3.9 GHz frequencies in a number of geographic locations in the coming months and years. [] It is therefore important that any new sharing mechanisms do not interfere with UKB’s use of the spectrum in its licensed band. 1 2 For more information, see Relish.net For example, Radwin’s Point to Point microwave equipment delivers throughput of 100 Mbps Ofcom’s proposal for a tiered authorisation approach to sharing in 3.8 GHz – 4.2 GHz In terms of channelling arrangements3, UKB occupies Ranges 4, 5 and 6 and we note that these are currently prioritised for UKB’s use. As a result there has only been one fixed link assignment in these ranges. We would expect any future sharing arrangements to continue to recognise UKB’s usage and avoid the possibility of interference in those Ranges. UKB operates radio equipment in this band using TDD at high power, therefore the risk of interference from other operators in the band would be significant. UKB’s licence is national in scope and UKB’s future deployment plans mean that no new geographic licences should be granted within the channel ranges occupied by UKB. Outside of these channels, UKB would have no objection to geographic licences being issued and would indeed view this proposal as an opportunity for itself to make greater use of the 3.8 – 4.2 GHz band. Any use of “opportunistic” licences should ensure no interference with UKB’s current or future use of its licence. Operators will, however, be limited by what technology is available in this band. The band is not widely used as yet and there is therefore only a limited range of equipment available. Smaller operators may struggle to attract the attention of OEMs in this space if they lack the necessary economies of scale. UK Broadband June, 2016 3 Figure 3 in the consultation document refers
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