WiMax Forum

12 September 2007

For more information, contact:

Chair, Regulatory Working Group

rwg-chair@wimaxforum.org

Radio Spectrum Policy and Planning
Ministry of Economic Development
Email: radiospectrum@med.govt.nz

Radio Frequency Auction: 2.3 GHz and 2.5 GHz Bands Discussion Paper

The WiMAX Forum¹ welcomes the opportunity to provide its views and comments concerning the issues raised in the above Discussion Paper.

The WiMAX Forum is an industry-led, non-profit corporation formed to promote and certify the compatibility and interoperability of broadband wireless products using the IEEE 802.16 and ETSI HiperMAN wireless MAN specifications. The WiMAX Forum’s goal is to accelerate the introduction of these devices into the marketplace. WiMAX Forum Certified™ products will be fully interoperable and support Metropolitan Broadband Fixed, Nomadic and Mobile Applications. For more information about the WiMAX Forum and its activities, please visit http://www.wimaxforum.org/.

The Forum is concerned about the comments in paragraphs 34 and 35 of the Discussion Paper under the heading “Lack of Technology Certainty”. WiMAX is not a technology that is frozen in time; just like all wireless technologies that will continue into the future, WiMAX is being enhanced with greater throughput and new features. To provide the certainty to allow large scale network deployments and volume production of commercial products, the WIMAX Forum has developed WiMAX Certification Profiles and a certification process for these Profiles. This provides the basis for the supply of interoperable network and consumer products to the global market. The Profiles will be developed further as the future WiMAX standards develop.

WiMAX is currently being deployed in both the 2.3 and 2.5 GHz bands, as well as other bands outside the scope of the Discussion Paper, and both network and CPE isavailable for both bands. The dominant band will be determined by spectrum availability for mobile broadband technologies across the globe and the cumulative level of investment in each band, however, the 2.3 and 2.5 GHz bands will both be major bands for WiMAX. While current subscriber stations (consumer equipment) are single band, these are is expected to be replaced by multi-band equipment.

WiMAX allows operators to follow different business models to cellular IMT technologies, even though it is currently being evaluated by the ITU-R for addition to the list of IMT technologies. The existing IMT technologies come from a voice centric background with data capability added, whereas WiMAX was designed as a wireless IP data network with voice being an application carried on that network. WiMAX is expected to be included in many consumer electronics devices that would benefit from connectivity, with many operators being far less focused on the handset model of current cellular technologies.

There is no need for those thinking about using WiMAX in New Zealand to be concerned about equipment being available for 2.3 or 2.5 GHz bands and re-tuning will not be required because the equipment is available in the respective bands.

The WiMAX Forum respectfully submits the comments in Annex 1 with regard to this consultation.

Yours sincerely
Tim Hewitt
WiMAX Forum

Chair - Regulatory Working Group

ANNEX 1: WiMAX Forum™ response to questions in Consultation Document

Responses to Questions

Question 1: Considerations Relating to Lot Design

1. Expected technical developments and likely demand. See covering letter.
2. Size and location of managed spectrum park or parks
   

The spectrum requirements for managed parks will depend on the New Zealand government’s expectation for use of the parks in terms of the number of spectrum users expected, the size of the area to be covered by each base station, the number of customers, whether it’s a rural or urban environment, whether coverage is fixed or mobile etc. Network planning issues such as co-location, channel width and power limits will also affect the amount of spectrum required.

  c. Acquisition limits

The WiMAX Forum will soon make the results of a study of the spectrum needs for WiMAX available on our Regulator Website. The study found that for the types of services expected in 2015, operators in a dense urban environment using 1 square kilometer cells would require 3 x 10 MHz of TDD spectrum to meet the peak hour demand. Hence the Forum recommends a minimum acquisition limit of 30 MHz of TDD spectrum per operator, excluding any spectrum whose primary use is to provide guard bands.

  d. Technical issues

Accommodating TDD and FDD

The WiMAX Forum has developed TDD Certification Profiles for 2.3 and 2.5 GHz bands. Development of an FDD profile in the 2.5 GHz band will depend on the future demand from operators for such a profile.

TDD and FDD can successfully co-exist in the same band under suitable technical arrangements as discussed in the WiMAX Forum Paper “Service Recommendations to Support Technology Neutral Allocations FDD/TDD Coexistence”. Interference between TDD and FDD operators is addressed in the Ofcom discussion document ”Award of available spectrum: 2500-2690 MHz, 2010-2025 MHz” of 1 August 2007 which examines the potential for interference and the measures needed to control interference.

The WiMAX Forum has a preference for the spectrum designated for guard bands between operators allocated to the operators to use to manage interference or for service provision if possible. This gives operators the flexibility to choose different options to mitigate interference including promoting cooperation between operators, coordination and site engineering. It also allows operators to change the measures they use as technology and business models develop and is a more efficient use of spectrum than the designation of fixed guard bands.

Guard Bands

WiMAX technology unwanted emission limits for 5MHz and 10MHz channel bandwidths have been submitted to ITU-R WP8F. Details for Base stations and for Mobile Stations operating at 2496-2690MHz can be found respectively in

ITU-R Document 8F/1329-E ‘Unwanted Emission Characteristics of IMT-2000 OFDMA TDD WMAN Base tations. This document is also available at: http://www.wimaxforum.org/technology/WiMAX_IMT_2000/8F_1329.pdf

ITU-R Document 8F/1330-E ‘Unwanted Emission Characteristics of IMT-2000 OFDMA TDD WMAN Mobile Stations. This document is also available at:
http://www.wimaxforum.org/technology/WiMAX_IMT_2000/8F_1330.pdf

A guard band between blocks that are assigned to different operators is usually required but the size of the guard band is dependant on many conditions relating to quipment performance, network density, specific features of the deployment scenario and other factors. For this reason the WiMAX Forum recommends that regulators do ot identify a specific guard band between licence blocks but instead make some allowance for this in the licence block and then allow operators to coordinate to maximize he use of their spectrum. As a guide and as concluded in several studies, generally a half channel to a single channel guard band is a good starting point and when no pecific guard bands are identified between blocks then this allowance should be included within the licence block itself. An example of this type of regulation can be found n ECC Recommendation (04)05 for BWA in the 3400-3600MHz frequency band in Europe.

The Forum supports the 5 MHz guard band proposed for New Zealand and its inclusion in the lots to be auctioned.

Question 2: Proposed Lot Design

2.3 GHz

The WiMAX Forum recommends the lot plan for 2.3 GHz as in Options A and C. Option B does not guarantee efficient use of the spectrum and allows bidders to block sensible outcomes by bidding in single lots.

2.5 GHz

This specific frequency range is addressed by the WiMAX System Profile for Mobile WiMAX (IEEE 802.16e-2005, OFDMA) equipment and its associated Certification Profile for TDD equipment based on 5MHz and 10MHz channel widths.

The WiMAX Forum supports a technology neutral spectrum licensing approach and, in particular, one that allows operators to decide as part of the spectrum allocation rocess whether they want FDD or TDD spectrum. This would include permitting TDD within that part of the spectrum that might be paired in some countries or regions and not restricting any spectrum allocated as FDD to remain FDD permanently. It would be desirable to retain the 120 MHz duplexing gap for any paired spectrum.

As a result the WiMAX Forum does not support any of the Scenarios proposed for this band. Choices made in the allocation process should determine the structure of the band.

The WiMAX Forum supports the award of the 2.5-2.69 GHz band at the earliest opportunity in order to enable presently unsatisfied market demand for high speed personal broadband services to be addressed and to give service providers the option to select Mobile WiMAX™ technology.

Question 8: Managed Spectrum Parks

b. The WiMAX Forum is unaware of any proposal to include a “listen before talk” feature in a WiMAX Certification Profile and suggests, if this requirement is to be included in technical requirements for managed parks, it be limited to those echnologies that have this feature.

Footnote

1 “WiMAX Forum® ” and “WiMAX Forum Certified™” are trademarks of the WiMAX Forum.