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Alactel-Lucent
ALCATEL–LUCENT RESPONSETO MED REQUEST FOR COMMENT MED Radio Frequency Auction 2.3GHz and 2.5GHz Bands
1 INTRODUCTION
2 COMMENTS RELATING TO OVERALL POLICY SETTINGS
2.1 Spectrum Trading
2.2 Use it or Lose it Clauses
2.3 Technology Neutrality
2.4 Lack of Technology Certainty
2.5 Minimum Frequency Requirements for WiMAX Provision
3 TECHNOLOGY NEUTRALITY IN THE 2.5-2.69 GHZ BAND
3.1 Question 1: Considerations Relating to Lot Design
3.2 Target for 2.5-2.69 GHz Bands
3.3 Use of Spectrum for Long Term Evolution (LTE)
3.4 Use of Spectrum for WiMAX 2005
3.5 Terms of Management Rights
CONCLUSION
CONTACTS
INTRODUCTION
Alcatel-Lucent thanks for the MED for this opportunity to provide comments on the paper “Radio Frequency Auction: 2.3GHz and 2.5GHz Bands”. Alcatel-Lucent supports the MED’s efforts to facilitate faster and cheaper broadband, via the investigation of new spectrum bands.
Alcatel-Lucent considers that communications in New Zealand faces two main challenges; 1) developing competitive high speed multimedia services in metropolitan environments and 2) providing service (fixed and mobile) with price parity between the metropolitan customers and the users situated in the remote areas of the country. We acknowledge the significant challenge of spectrum authorities to manage both in an equitable and efficient manner. This is exemplified by the MED’s effort to redefine the structure of licenses and create clearance of key globally ratified spectrum bands.
The three key expressions highlighted in this document are:
- Global developments are driving technology and service neutrality of spectrum strategies in a similar manner to the MED’s approach.
- Strategies for allocation of the 2.5-2.69 GHz need to consider the requirements for mobility extended services in addition to Broadband wireless access. It is recommended to adopt a technology neutral approach, allowing for either mobility or broadband wireless requirements, driven by commercial demands.
- Allocation of usable spectrum amounts as a “Managed Park” is innovative and should enable targeted broadband services for communities and industry vertical services. Some of which may not be participating in this process.
Alcatel-Lucent would welcome the opportunity to conduct follow up discussions with MED regarding this subject.
About Alcatel-Lucent:
Alcatel-Lucent provides solutions that enable service providers, enterprises and governments worldwide, to deliver voice, data and video communication services to end-users. As a leader in fixed, mobile and converged broadband networking, IP technologies, applications, and services, Alcatel-Lucent offers the end-to-end solutions that enable compelling communications services for people at home, at work and on the move. With 79,000 employees and operations in more than 130 countries, Alcatel-Lucent is a local partner with global reach. The company has the most experienced global services team in the industry, and one of the largest research, technology and innovation organizations in the telecommunications industry. Alcatel-Lucent achieved proforma combined revenues of Euro 18.6 billion in 2005, and is incorporated in France, with executive offices located in Paris. [All figures exclude impact of activities to be transferred to Thales]. For more information, visit Alcatel-Lucent on the Internet: http://www.alcatel-lucent.com.
2 COMMENTS RELATING TO OVERALL POLICY SETTINGS
2.1 Spectrum Trading
Alcatel-Lucent supports the need for post auction spectrum trading understanding that the business environment of these networks is impacted by a number of variables external to the control of the network operator. Principally:
- Changes in end user services can drive new requirements for spectrum resources into the future
- Competition from traditional mobile and especially fixed services may require additional bandwidth to be developed at constant revenues
- Wholesale Broadband Policy
The ability to acquire or dispose of spectrum licenses w ill allow industry the flexibility to adjust to the business environment, while still providing competitive end user services.
2.2 Use it or Lose it Clauses
“Use it or Lose it” clauses are a valuable mechanisms to ensure that the scarce resource of spectrum does not go to waste. In this regard, Alcatel-Lucent supports the M ED’s initiative. How ever as discussed in the MED paper, some degree of flexibility in the introduction of new technologies is sometimes warranted. In this way, as the case by case basis mentioned by the MED, Alcatel-Lucent recommends the MED approaches such situations with the understanding of the best time of deployment be judged based on the long term interest of end users. A clear example is the intentions of license holders to deploy LTE (Long Term Evolution) or WiMAX (WorldWide interoperability for Microwave Access). In this situation the “use it or lose it” clause of a WiMAX network operator should arguably be earlier than LTE given current state of global availability and maturity.
2.3 Technology Neutrality
Alcatel-lucent supports the MED’s policy for technology neutrality. In a broad approach this is consistent with the work that Alcatel-Lucent undertakes in the research and development and involvement in the various standard bodies. Alcatel-Lucent would recommend that this neutrality be extended to the facilitation of appropriate guidelines implementation of main technologies such as WiMAX and IM T2000 advanced in the 2.5-2.69GHz band.
2.4 Lack of Technology Certainty
It is Alcatel-Lucent belief that statements within the MED’s paper on risks for development for either 2.3 or 2.5 GHz are already negated by deployments proven in the field. Alcatel-Lucent in fact is already undertaking greater than 12 network builds (70+ trials) with WiMAX-2005 covering all of the main bands (being 2.3-2.4 GHz, 2.5-2.7 GHz and 3.4-3.6 GHz). It is clear from both the network infrastructure and customer device side that all these bands are and will be broadly available at the same price points.
2.5 Minimum Frequency Requirements for WiMAX Provision
It is generally stated by industry that 30M Hz is sufficient for the provision of a wireless broadband network. Alcatel-Lucent highlights how ever that depending on the specific market position of the provider this may vary considerably. In one case an operator positioned mostly for voice and ‘lighter services’ such as mobile broadband would find 30M Hz sufficient for the capacity requirements even in the largest city such as Auckland. How ever a provider principally positioned into the fixed wireless substitute market (i.e. carry wire line subscriber profiles) may require substantially more (60M Hz+). Alcatel-Lucent’s experience is that requirements for higher throughputs and higher download volumes is ever increasing, underpinned by higher reliance upon the Internet, working from home, gaming, VOIP and emerging
applications expected to dominate future traffic requirements such as on-demand entertainment. Such assumptions could easily underpin a spectrum requirement of 60 MHz or more in the 2008/09 time frame, at a time when competitive networks will likely be launched. Alcatel-Lucent modelling undertaken with its customers consistently highlights the technology and economic advantage of additional spectrum. In this respect, spectrum amount is an important factor is the creation of a sustainable business. Fragmented spectrum increases the difficulty or even prevents offering higher throughput and higher capacity broadband services. W hen compared with fewer providers with less fragmented spectrum, having many providers with fragmented spectrum would impede sustainable competition from wireless operators in the rapidly emerging Unbundled Local Loop (ULL) (fixed) market.
3. TECHNOLOGY NEUTRALITY IN THE 2.5-2.69 GHZ BAND
3.1 Question 1: Considerations Relating to Lot Design
Alcatel-Lucent supports regulatory approaches that allows for technology neutrality and flexibility required for new services. In a technical sense this approach is somewhat divergent in the need to allow for TDD/FDD co-existence and support the largest channels sizes enabled by new technologies (generally 10M Hz with a requirement for 20M Hz to extract the highest performance). Additionally policies supporting end user interest, requires that competition i.e. multiples of spectrum licenses be allocated. All of this combined creates pressures on spectrum resources which typically cannot be accommodated within a singular band. A degree of compromise is inevitable.
3.2 Target for 2.5-2.69 GHz Bands:
In the 2.5G Hz band under planning by the M ED, Alcatel-Lucent is developing two principal technologies. Both of these standards are common in that the likely main band for deployment is not the only option and that larger channels sizes will be available. It should be noted that while other bands are available, it is recommended that the interests of end users would be best served via alignment to global volumes.
3.3 Use of Spectrum for Long Term Evolution (LTE):
Figure 1.1 Long Term Evolution, Target Spectrum Bands LTE deployable in any of the “3G PP” bands,… (and more)
(2.5/2.6 GHz, 2.1 GHz, 1900 MHz, 1800 MHz, 1700/2100 MHz, 900 MHz, 850 MHz,… (700 MHz, 450 MHz) 2500-2690M Hz (IMT 2000)
3.4 Use of Spectrum for WiMAX 2005
Figure 1.2 WiMAX -2005 Spectrum Bands
Alcatel-Lucent recommends that the M ED allow for flexibility in future technology deployment in the 2.5- 2.69G Hz band. This will require the support for both paired FDD and unpaired TDD channel arrangements. Based on the MED paper this aligns itself towards the adoption of Option C (i). It is recommended that version ‘(i)’ be adopted since clarification of FDD/TDD channel will allow for specific details such as the design of spectrum masks, that will minimise interference in the zones of adjacent TDD and FDD uplinks.
These design considerations are currently undergoing development in international bodies such as the ITU-R WP8f and the WiMAX forum regulatory working group.
3.5 Terms of Management Rights
Question 4: Eligibility to Bid
In the discussion of promotion of competition and the resulting restrictions of incumbents to bid, Alcatel-Lucent would like to point out the distinction between possible usages of 2.3G Hz and 2.5G Hz bands. While can be argued that WiMAX is a disruptive technology and therefore provides potential for competitive industry development, it has the option of deployment in either the 2.3-2.4G Hz or 2.5- 2.69G Hz bands. The deployment of LTE is dependent on 2.5-2.69G Hz in this auction process.
In the New Zealand environment the 2.5-2.69G Hz band could play a pivotal role in the development of next generation multi-media based mobility services. Given the rapid state of innovation of these services globally, and the degree of unknown to which consumer demand could build, it would therefore be premature to exclude the incumbent mobile operators from the considering this evolution of their businesses. A distinction between the 2.3-2.4G Hz and the 2.5-2.69 GHz is therefore recommended.
CONCLUSION
The major challenge is to develop a spectrum management framework that supports innovation in radio communications independent of spectrum usage linked to underlying technology or the type of service. Such a framework is needed not only to satisfy the engineering, economic and policy challenges of future spectrum usage, but also to satisfy increasing end–user demand and quality of service requirements. This situation is not unique to New Zealand but common to all the markets that Alcatel-Lucent operates in.
In conclusion, the three key summary points highlighted are:
- Global developments are driving technology and service neutrality of spectrum strategies.
- A strategy for allocation of the 2.5-2.69G Hz needs to consider the end user requirements for mobility services in addition to wireless access. It is recommended to adopt a technology neutral approach, allowing for either mobility or broadband wireless requirements, driven by commercial demands.
- Allocation of usable spectrum amounts as a “Managed Park” is innovative and should enable targeted broadband services for communities and industry vertical services. Some of which may not be participating in this process.
Alcatel-Lucent would welcome the opportunity to conduct follow up discussions with MED regarding this subject. Contact details are provided below.
CONTACTS
Alcatel-Lucent Australasia:
Frank Louwdyk
Phone +61 2 83065466
Email frank.louwdyk@ alcatel-lucent.com.au
BEN CHRISTIAN
Phone +64 4 803 7433
Emailben.christian@ alcatel-lucent.co.nz
