Response to Ofcom`s Call for Inputs on Opportunities for Innovation

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