Responses to Questions on ICASA Discussion Document On Dynamic And Opportunistic Spectrum
SubmittedBy: Tim Shete / Company: Morai Telecommunications21 Woodlands Drive
Building 2, Country Club Estate
Woodmead, Johannesburg, 2191
+27 11 258 8740 (office)
+27 84 863 1609 (mobile)
(e-mail)
Signature: / Morai Doc #: Mor_TVWS_01
Date Submitted: 11/12/2015 / ICASA Notice #: 39302
Question # / ICASA Question / Morai Telecoms Response
1 / Do you agree that ICASA has the appropriate legislative mandate to address the issues of dynamic and opportunistic spectrum management and TV White Spaces and to build a suitable framework? If the answer is no, please elaborate / Yes we agree. Sections 2, 4, 30 and 33 of the ECA Act of 2005 and Sections 4(3) (c) and 4B of the ICASA Act of 2000 form the basis that supports the view that ICASA does indeed have the appropriate legislative mandate to address the issues of dynamic and opportunistic spectrum management and build a suitable TVWS framework.
2 / Are there any existing licensing models overlooked here? / The seven mentioned in this discussion paper cover most of the typical and popular licensing models that are employed by regulators throughout the world.
3 / Do you have any comments about these four areas of spectrum reform? / 3.1By finalizing the rules to make the unused spectrum in the UHF DTT band available for unlicensed broadband wireless devices should count amongst one of the groundbreaking steps that ICASA has taken in a long time. This particular spectrum hasexcellent propagation characteristics that allow signals to reach further and penetrate walls andother structures. Access to this spectrum could enable more powerful public Internetconnections such as super Wi-Fi hot spots with extended range, fewer dead spots, and improvedindividual speeds as a result of reduced congestion on existing networks. Many otherapplications are possible, such as broadband access for agricultural purposes and for schools and medical facilities particularly in rural areas, campusnetworks that are better able to keep pace with users’ increasing demands for bandwidth, homenetworks that are better able to support real time streaming video applications, remote sensing ofwater supplies by municipalities and support for the smart grid. The potential uses of thisspectrum are limited only by the imagination.
3.2The DSA framework will also lead to workable coexistence spectrum sharing approaches that will greatly assist in improving spectrum efficiency in the DTT UHF band and spur investment and innovation in applications and devices that will be used not only in the TV band but eventually in other frequency bands such as above 50GHz and in the 5 GHz bands as well. The planned 700 MHz contiguous spectrum could be implemented for the balance of the 5150 MHz band together with the license exempt implementation in this band and could provide important additional capacity for Wi-Fi at 5 GHz.At above the 50 GHz bands implementation this will help to reduce the risk of prohibitively high license prices.
3.3PLC is another area of interest for broadband development but will be challenging in practice to be able to control interference and the transmissions over a power line.We await in anticipationconclusive research on viable and practical implementations of this technology to be accepted by industry.
4 / Do you favour making more license exempt spectrum available in the 5 GHz band? / Yes, as mentioned above in (3.2), this could assist in improving spectrum capacity and efficiency in the 5 GHz band and spur needed investment and innovation in applications and devices that will be used in this band.
5 / And in any other bands? Be specific, please, and support your recommendations / Noother bands at this time.
6 / Do you believe that the Dynamic Spectrum Assignment approach is viable and worthwhile? / Yes most definitely. Dynamic spectrum allocation using databases is a new and flexible spectrum access method and technology that can be used to maximize the spectrum resource. Moreover, it has so far proven that it can be deployed without causing harmful interference to incumbent operators and as such we expect its implementation to improve and evolve over time. It is therefore a viable and worthwhile exercise to pursue.
7 / Do we have enough data about the TV broadcast transmitters to be able to model their propagation accurately? / It is advisable to always scan an area to be deployed to determine if records and RF broadcast pattern predictions are up to date before a deployment in an area as most often the “known” data required for accurate modelling may itself be inaccurate or incorrect.
Furthermore, the available and known data about the TV broadcast transmitters is a good start but is in no way sufficient for purposes of analysing coexistence between DTT and other services such those provided by WSDs for instance. Whichever DTT propagation analysis model or planning tool may be/has been chosen to be deployed in South Africa, its output will always only be adequate for estimating gross DTT coverage in South Africa but will fall shortwhen used for purposes of accurately estimating the number of locations which may suffer harmful interference caused by WSDs. It is just one parameter that needs to be calibrated in conjunction with several others in order to produce a model that results in a low overall probability of harmful interference.
Further extensive evidence from real-life situations testing conducted in laboratories, pilots, field tests, and tests in a sample of households in selected areas of the country would need to be undertaken. In addition, the SABC, eTV, Mnet and Sentech (who operate the DTT infrastructure in the SA) have to conduct their own tests and provide additional data to supplement this data.
8 / Does enabling the operation of TVWS contribute to the objective of ensuring efficient use of radio frequency spectrum? / Yes, the interference free coexistence framework approach with DTT primary incumbents that TVWS advocates in the UHF band, coupled with the geo-location database governed opportunistic spectrum sharing and usage by WSDs on a secondary assignment basis is the best contribution by TVWS technology towards achieving the goals of ensuring the most efficient uses of radio spectrum.
9 / Do you believe that it will also further objectives of encouraging investment and innovation in the electronic communications sector? / Yes, we know from traditional Wife experience that unlicensed spectrum can trigger unexpected but hugelybeneficial innovation in the electronic communications sector. Since TVWS is more robust and travels longer distances and through walls, it makes the electronic communications sector potential innovation and investment in this unlicensed spectrum much greater this time around. It will allow manufacturers to begin manufacturing and marketing unlicensed communications devices and systems that operate on frequencies in the TV bands more aggressively.
10 / What are the benefits that could be expected from making TVWS available? / 10.1TVWS availability will spur industry to
come up with a varied range of potential use cases and applications such as database systems development, cognitive technology systems development, Super Wi-Fi and Wi-Fi offload, webcam backhaul, CCTV monitoring, remote sensor monitoring, M2M (machine to machine communications), digital signage, mining, marine and rural broadband to name but a few. For South Africa, rural broadband is probably the most important.
10.2Due to the nature of rural topography and the lack of available grid power in SA, TVWS, being a Sub 1Ghz technology, will have far better propagation across this terrain and will be able to operate in a "near line of sight" (NLOS) mode. This will allow areas to be reached in a far more economical manner so as to be able to provide affordable internet access and reliable grid power, especially renewable energy power solutions, to potential users at the bottom of the income pyramid.
10.3Making TVWS available is not only attractive for the innovation, investment andeconomic benefit it will unleash, but because of the competitive edge it will offer. Many tech companies are already investing in research and development of super Wi-Fi and cognitive technologies. Now they can take these technologies out of the labs and onto the market.
10.4The hugeopportunity for job growth associated with this spectrum will not only be beneficial for a depressed and job hungry economy like we have in SA but will help put out new and small telecommunications operators on a regional and national basis much faster.
11 / What are the disadvantages that could be expected from making TVWS available? / TVWS availability will cause widespread market disruptions to traditional wireless broadband providers’ revenues whose prices to consumers remain high as they will provide cheaper broadband access alternatives to a much broader community of consumers.
Thus we expect big telecoms operators and traditional ISPs to try to come in and control and manipulate influence the TVWS market so as to ensure that it does not adversely affect their businesses.
12 / Do you foresee any risks? / 12.1There should be a structured use of the DTT planning tool and the propagation analysis model of choice for SA with real-life sample testing of WSDs inference using actual transmitters in use per location in order to obtain reliable data so as to avoid the risk of overprotecting DTT incumbents and therefore resulting in unnecessary spectrum sterilization.
12.2Qualification of new TVWS operators must include the region of interest, a brief business plan and follow the normal ICASA application for sub 1 GHz frequencies but incorporating further detailed information on the WSD devices and radio equipment to be used to ensure technology compliance and hence lower the risk of interference to incumbent operators.
13 / Does it support SA Connect goals regarding the deployment and adoption of broadband? / Yes, very much so in that the SA Connect policy identifies making significant amounts of otherwise underutilized spectrum available for broadband use as holding promise for increasing South Africa’s broadband capacity. The proposed regulatory framework for dynamic spectrum assignment would enable the widespread utilization of this underutilized spectrum and in doing so promote more efficient use of available spectrum. It is another implementation of an important recommendation of the National Broadband Plan, which emphasizes the vital role of spectrum to our economic future and the need for spectrum efficiency, spectrum recovery, and smart spectrum policy.
14 / What mechanisms should be put in place for dynamic spectrum assignment in meeting future demand for spectrum? / 14.1The first step would be to implement a workable TVWS framework based on the Ofcom model but tailored for SA. This will act as an appropriate starting point for proceeding with implementing the authorisation of use of WSDs in the UHF TV band. It will offer a viable way forward that can be implemented now but one which is anticipated can be refined in the future to meet the objective of ensuring efficient use of the UHF TV band.There should then be a follow up general review of the effectiveness of the TVWS framework and suggest doing this within the first 18 months of operation.
14.2The second step would be to establish a TVWS Technical Working Group whose focus will be on providing ICASA with technical evidence to assist in ensuring that the coexistence framework continues to result in a low probability of harmful interference and, consistent with that objective, facilitating the use and development of the TVWS framework. If the results prove beyond a reasonable doubt that the TVWS framework works, it can then start to be implemented in other bands in a phased approach.
15 / Could TVWS provide increased consumer value and/or improved social and economic inclusion? / Yes most definitely. Connecting the unconnected to the Internet has many positive advantages for the community. The Internet supports development by transforming a younger generation’s ability to acquire knowledge, skills, employment and entrepreneurial appetite and contributes productively to national growth. It can also help an ageing population to remain active and access cost-effective health care. Connectivity is transforming agriculture, farming, transport, manufacturing, logistics and environment management to name but a few economic sectors. All forms of government can achieve greater efficiency and cost-effectiveness through their citizens being online and connected.
16 / What impact is the digital switchover expected to have on the use and availability of TVWS? / After the analogue to digital migration and subsequent restacking, there will be a significant increase in the available channels for TVWS as digital TV is far more efficient in the use of each channel. About 75% of spectrum will remain unused in any one of the 11 regions as only four channels are required to receive the 4 multiplexes at any given location. Except on the border areas, 168 MHz will be available for TVWS use.Since it has also been shown that TVWS can exist in adjacent channels to existing high dense analogue Terrestrial Broadcasting as demonstrated in the Western Cape, TENET pilot project, the Digital switch over will reduce the number of Transmitter sites to the planned 189 DTT sites meaning that most the >1000 analogue sites may be switched off thus increasing the spectrum resource.
17 / Do you believe white spaces should be utilised without authorisation or licensing? / No, that would be dangerous and detrimental to the entire DTT UHF band ecosystem as there would never be any way to guarantee the quality of service if any WSD can simply start transmitting and cause interference to one or any other device with no means of identifying eliminating the source of that interference.
A certain amount of regulation is therefore necessary to authorise access to TVWS and to protect the existing users. However, the regulatory burden should be minimized as much as possible so as to be consistent with the need to prevent undue interference, in order to maintain flexibility.
18 / Should there be rules for such usage? / Yes, in order to ensure interference free coexistence with DTT and between TVWS operators, it is imperative that there should be technology operational rules and device certification/approval rules for all TVWS operators and database administrators.
19 / Does the advent of TVWS have the potential to remove the existing “spectrum scarcity”, at least in some bands? / Yes to a certain extent. It will allow more users of a spectrum which is totally underutilized, especially in rural areas. This in turn will allow otherwise unused UHF spectrum to be used – often many times over in different areas – thus relieving the so-called “spectrum scarcity”.
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21 / Is there a space for license-exempt, unmanaged use of TVWS? / No, there is no space for license-exempt, unmanaged TVWS use due to the fact that an unmanaged licensing model does not easily lend itself to interference mitigation with existing broadcasting services.
22 / Is there a space for license-exempt, managed use of TVWS? / Yes definitely. A license-exempt, managed TVWS licensing model perfectly lends itself to interference mitigation with existing broadcasting services. Licensed exempt spectrum can also trigger unexpected but hugelybeneficial innovation.
23 / Is there a space for licensed use of TVWS? / Yes, but only for select applications such as point-to-point backhaul. On the whole and for the bulk of the other applications, TVWS use should remain license exempt so as not to increase the cost of being able to provide affordable internet connection to those who desperately need it and also greatly increase the regulatory and administration burden to both the Authority and the operators.
24 / If so, should licensed users pay the minimum annual fee, or a fee proportionate to use? / Licensed users should only pay the minimal annual fee. If the minimal annual fee is excessive it will be uneconomical for any enterprise to make a profitable business case in order to be able to provide and create the many new employment opportunities in the rural communities for the support and maintenance of the networks and its customers.
25 / Does the combination give us the best of both worlds? / Yes it does.
26 / Which of the licensing regimes do you favour? Why? / Mixed licensed regime. A license-exempt, managed TVWS licensing with select licensed applications model perfectly lends itself to interference mitigation with existing broadcasting services.The licencing model should be tailored to entail the least regulatory and administrative burden compared to other forms of authorisation so that it removes barriers to access to the spectrum, foster innovation and competition in the development of WSDs, and thereby result in benefits to consumers.
27 / Rank the licensing regimes in order of preference with reasons for your preferred order. / 27.1Mixed Regime - This has real benefits in the hierarchy proposed especially for fixed licensed Point-to-Point backhaul use of TVWSbut may be a bit complicated to implement a special case of the licensed use provision of protection to select WSDs while also advocating a license exempt regime for TVWS.
27.2Managed License exempt - this has shown to be most effective in the trial operation worldwide which has been successfully adopted by some regulators already. With the spectrum database under control, one can ensure that devices are protected not only from one another but across co-located networks.
27.3Light Licensed Regime -Perhaps a light fee per base station and not per device could be considered to ensure the registration of the location of the transmitter sites that control the channel connection with the WSDs.
27.4Fully Licensed Regime - the concern here is that the fees being charged could increase the cost to provide the TVWS service making it impossible for operators to provide an affordable offering. It will also greatly increase the regulatory and administration burden to both the Authority and the operators.
28 / Do you see this as possible? Why / why not? / Yes automatedlicensing is definitely possible. However, the AIP license fee calculation would kill the TVWS business especially if the number WSDs in use rises exponentially so we advise that no fee structure should be imposed.
29 / Does this provide a significant improvement on the status quo? / It will provide an improvement in that it entails the least regulatory and administrative burden compared to other forms of authorisation, such as individual licenses especially considering the multitude of users and operators to be managed.