A framework for spectrum sharing consultation response October, 2015
Nominet UK: Company limited by guarantee Registered in England: Not for profit Company No. 3203859 VAT No. GB 663 4990 03 Registered Office: Minerva House, Edmund Halley Road, Oxford Science Park, Oxford, OX4 4DQ
Contacting us Phone: 01865 332403 Email:
[email protected] Write to: Nominet UK, Minerva House, Edmund Halley Road, Oxford Science Park, Oxford, OX4 4DQ Web: www.nominet.org.uk
T +44 1865 332211 F +44 1865 332299 E
[email protected] www.nominet.org.uk
General response Introduction About Nominet Nominet is the private not-for-profit company responsible for running the .uk internet domain name registry. We are a medium sized company employing approximately 150 people in Oxford, London and Cardiff. Nominet’s articles of association commit the company to working for the public benefit and since 2008 any surplus generated by the company has been donated to our charitable foundation, the Nominet Trust. We are now starting to use the technical expertise within the company to explore new business opportunities in areas such as cyber security, smart cities and the Internet of Things and are investing heavily in research and development. Nominet’s involvement in TV White Spaces Over the past two years, Nominet’s R&D team has built a TV White Space (TVWS) database and qualified for participation in Ofcom’s pilot scheme as a White Spaces Database (WSDB) provider. The on-going collaboration between Nominet, Ofcom, and the other stakeholders has helped inform Ofcom’s development of the TVWS regulatory framework. Our WSDB has been used for academic research, for exhibits (e.g. at the Glasgow Science Centre during the Commonwealth Games), and in two live trial projects. Most notably, Nominet has deployed prototype TVWS hardware to enable real-time time measurement of Oxford’s streams and rivers as part of a local community project called the Oxford Flood Network. This has demonstrated a practical use of TVWS in enabling Internet of Things applications. In Oxford people are installing their own water-level monitoring sensors in order to share local information and knowledge about rivers, streams and groundwater to build a better, hyper-local picture of the flood risk at high-resolution and at street level on the streams, groundwater and the complex basin of the Thames and Cherwell rivers. Following Ofcom’s decision to release TV white spaces for use at the end of 2015, Nominet was the first company to successfully complete the qualification process for its WSDB. These research projects have provided Nominet with practical experience of working with all the components of the TVWS framework and we expect these will be the basis of the frameworks for spectrum sharing in other bands.
Nominet UK: Company limited by guarantee Registered in England: Not for profit Company No. 3203859 VAT No. GB 663 4990 03 Registered Office: Minerva House, Edmund Halley Road, Oxford Science Park, Oxford, OX4 4DQ
T +44 1865 332211 F +44 1865 332299 E
[email protected] www.nominet.uk 2
Summary of Nominet position Nominet is largely in favour of the creation of a regulatory framework for assessing opportunities for spectrum sharing. We believe that more information should be collected about real spectrum usage in order for Ofcom to design the framework and for the industry to assess the opportunities. We believe it is fundamental that Ofcom clearly and explicitly states that spectrum sharing will be the default way to access spectrum and that priority and exclusive uses will be part of the framework as ad-hoc additional levels of permission. A combination of geo-location databases, access control technologies, and data analytics will allow Ofcom to maximise the efficiency of the spectrum usage, to maximise the value of this finite resource, to lower barriers to access in established markets, and to foster the growth of new niche ones. In particular, the use of geo-location databases would allow regulators to test and implement policies very quickly, thus massively lowering the cost of developing spectrum reforms; the use of cognitive radios and access technologies will allow Ofcom to optimise the spectrum use locally; the use of data analytics will allow the industry and users to evaluate market opportunities more thoroughly.
Nominet UK: Company limited by guarantee Registered in England: Not for profit Company No. 3203859 VAT No. GB 663 4990 03 Registered Office: Minerva House, Edmund Halley Road, Oxford Science Park, Oxford, OX4 4DQ
T +44 1865 332211 F +44 1865 332299 E
[email protected] www.nominet.uk 3
Responses to questions Question 1 Do you have any comments on the barriers to increased sharing that we have identified above? Which are the most significant and why? Are there others we should take into account? We agree with the analysis about the barriers to spectrum sharing. The existing means of obtaining spectrum are beset with complexity, obscurity, and fragmentation. Without data about spectrum use it becomes difficult to evaluate and identify opportunities. The lack of such information is one of the reasons why the development of new regulatory frameworks takes a long time. The mismatch between innovation rate and the time required to implement a regulatory reform makes it difficult for companies - especially startups and SMEs - to base their strategies around spectrum opportunities. If not addressed, this lock of information could ultimately affect the overall success of managing spectrum in a smarter and dynamic way. Question 2 Have you experienced or are you experiencing the effects of these barriers? If so, in what circumstances and with what impact? In 2005 Ofcom published a consultation about what use could be made of the spectrum freed up by the Digital Switchover. This led to the publication in 2009 of a document in support of cognitive access. The development of a framework for dynamic use of the White Spaces within the UHF band, its evaluation through a pilot phase, and its implementation took many years to complete. This delay has led small companies to abandon the TVWS opportunity altogether. We have experienced this first hand with the lack of competition and fast iterations on the product development that currently exists in the radio hardware market. We believe TVWS to be the first important step for dynamic spectrum management. Similar processes can be applied to other bands, and present benefits for regulators, industry and users. However, processes should take less time and Ofcom should clearly state that sharing spectrum is the preferred way to accessing spectrum and that priority and exclusive users are only specific cases within a sharing framework. By doing so, companies will develop more robust business strategies and also come up with innovative ones which might not only increase the efficiency of the spectrum use, but also foster innovation through for example lowering barriers between telcos and small companies which want to enter in the market. We finally note that spectrum harmonisation both at European level and worldwide will help lower development costs for industry by enabling greater economies of scale. Question 3 Are the categories of information set out in paragraph 5.5 the right ones? Are there any areas here that you think we should prioritise? Are there other types of information that we should be improving? Information on actual use should also consider past usage, possibly aggregated and managed appropriately as some data could likely be considered commercially sensitive. There is currently little Nominet UK: Company limited by guarantee Registered in England: Not for profit Company No. 3203859 VAT No. GB 663 4990 03 Registered Office: Minerva House, Edmund Halley Road, Oxford Science Park, Oxford, OX4 4DQ
T +44 1865 332211 F +44 1865 332299 E
[email protected] www.nominet.uk 4
motivation for commercial users to publish their actual spectrum usage, which is a major barrier that Ofcom should look to address. Question 4 Do you think the information about spectrum characteristics described in paragraph 5.9 would be useful? What information would need to be included as a minimum to make it useful? Yes, we believe it would. In addition, further details will be needed to properly assess the potential to share spectrum, including permitted power levels, adjacent band compatibility issues, and opportunities for international harmonisation. Question 5 Have we identified the relevant market enablers, or are there others we should take into account? For each one, what is the potential for it to facilitate sharing and what are the downsides? Are there any that you think would be particularly effective or problematic? We observe in general that unified, widely-available, easy-to-use processes are more likely to elicit widespread usage than fragmentary, exclusive, obfuscated processes. As an additional market enabler, we therefore propose that the enablers listed in this document should be components of a single integrated Spectrum Sharing Software Platform. Such an online platform could bring together a userfriendly searchable spectrum authorisation and use registry with convenient means to obtain permission for spectrum usage. An online platform could also integrate online license applications, trading and auction marketplaces, and geo-location services. We believe that a unified online platform would deliver significantly enhanced usability for all stakeholders which should be an important underpinning of Ofcom’s approach to spectrum sharing. Question 6 Have we identified the relevant technology enablers, or are there others we should take into account? For each one, what is the potential for it to facilitate sharing and what are the downsides? Are there any that you think would be particularly effective or problematic? What, if any, role should Ofcom play in helping to develop them? Ofcom should play a leading role in the global standardisation and spectrum harmonisation to enable current sharing technologies to evolve. We believe that Ofcom correctly identified all the most relevant technology enablers. Some of those are already present in the TVWS framework, and therefore could be used by the regulator and the industry to test incremental policy changes in a shorter timeframe. As a first step, for example, priority for PMSE uses could be directly handled by the TVWS geo-location database, thus introducing within the framework the real-time handling of different classes of service (as presented in §5.38 of the consultation document).
Nominet UK: Company limited by guarantee Registered in England: Not for profit Company No. 3203859 VAT No. GB 663 4990 03 Registered Office: Minerva House, Edmund Halley Road, Oxford Science Park, Oxford, OX4 4DQ
T +44 1865 332211 F +44 1865 332299 E
[email protected] www.nominet.uk 5
Moreover, other elements like power constraint, real-time spectrum availability feedback, and mobility should be investigated more in detail to make the regulatory framework more powerful and flexible. Question 7 Do you have any comments on the authorisation tools that we have identified above? Are there others we should take into account? For each one, what is the potential for it to facilitate sharing and what are the downsides? Are there any that you think would be particularly effective or problematic? Nominet agrees with the authorisation tools identified by Ofcom and does not have further comments. Question 8 Are the characteristics of use we have identified sensible and sufficient to provide a high level indication of sharing potential? Are there other factors that we should expect to take into account? Are there any factors that you consider to be particularly significant? Are there any which we should attach less weight to? With respect to Table 1, we do not have further characteristics to propose. We propose that in the investigation for spectrum the opportunity for spectrum sharing should start from bands where the spectrum value and the benefits of international harmonisation are higher. We believe that Ofcom should take a strong position about the opportunity to share spectrum. In fact, Ofcom should clearly state that sharing will eventually become the default way to access spectrum and that the way it will be applied will be considered on a case by case basis. If Ofcom does not make clear that it believes sharing is one of the fundamental ways to meet the increasing demands for spectrum then the industry will be unable to respond appropriately with new innovations in this space. This is likely to delay regulatory changes, as it will appear as if there is less demand. Ofcom should consider spectrum sharing as regulation that enables innovation and therefore, by definition, it is not possible to fully define what the market outcomes will be in advance of the changes in regulation.
Nominet UK: Company limited by guarantee Registered in England: Not for profit Company No. 3203859 VAT No. GB 663 4990 03 Registered Office: Minerva House, Edmund Halley Road, Oxford Science Park, Oxford, OX4 4DQ
T +44 1865 332211 F +44 1865 332299 E
[email protected] www.nominet.uk 6
