Radio Spectrum Management Strategy Statement 2019 to 2021
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Radio Spectrum Management Strategy Statement 2019 to 2021 ComReg Document Number: 18/118
Contents Foreword2 Introduction4 2.1 Background and Purpose 5 2.2 Structure of this document 7 The Framework for Spectrum Management in Ireland 8 3.1 Spectrum Policy and Management in Ireland 9 3.2 Spectrum Management 10 Factors informing ComReg’s work plan for 2019 – 2021 22 4.1 International harmonisation of radio spectrum 23 4.2 European Commission harmonisation decisions 25 4.3 End user demand for mobile data 32 4.4 Technology changes and advancements 34 4.5 Licences expiring in the near future 39 Radio Spectrum work plan for the period 2019 – 2021 42 5.1 Appropriate prioritisation of spectrum work activities 43 5.2 ComReg’s spectrum work plan 2019 to 2021 44 Annex 1: Summary of legal framework and statutory objectives relevant to the management of the radio spectrum 48 A2.1 Primary Objectives and Regulatory Principles under the 2002 Act and Common Regulatory Framework 49 A2.2 Other Relevant Obligations under the Framework and Authorisation Regulations 53 A2.3 Other Relevant Provisions 56 Annex 2: Spectrum Designators 58 Mobile Phone Repeaters FAQs 59
1 Foreword This strategy statement sets out ComReg’s work plan and priorities for the next two years in relation to its role as Ireland’s spectrum manager and complements ComReg’s Electronic Communications Strategy Statement. 2 Radio Spectrum Management Strategy Statement 2019 – 2021
I am pleased to present the Commission for enhanced mobile broadband services, they 1 See ComReg Document 18/60, Communications Regulation’s Radio Spectrum will also enable applications that connect which proposed Management Strategy Statement for Ireland massive numbers of devices for machine-to- an award of spectrum rights for the period 2019 to 2021. machine communications, and applications in the 700 MHz Duplex, Paired that require ultra-reliable service levels 2.1 GHz, 2.3 GHz Radio frequencies are used to provide a that cannot be guaranteed with today’s and 2.6 GHz frequency bands. wide range of electronic communications technology. Examples of applications that 2 ComReg’s services and applications for the benefit have been suggested include connected Electronic Communications of society. Citizens use radio frequencies self-driving vehicles, smart agriculture, smart Strategy when they make a mobile phone call or use manufacturing and telemedicine. Statement 2017– 2019 – https:// mobile data, when they listen to the radio www.comreg. or watch broadcast TV, and when they Over the past several years, ComReg has ie/publication/ electronic- use a contactless card to make a payment licensed a considerable amount of spectrum. communications -strategy- or enter a building. Radio frequencies are This has enabled explosive growth in the use statement used to keep planes flying safely, to ensure of mobile broadband services. We were also -2017-2019/ smooth operations by our defence forces and among the first in the EU to license the 5G public safety services, and to support many pioneer band at 3.6 GHz. In the forthcoming private businesses. period, ComReg will further develop and finalise its multi-band award proposals for the The wireless telecommunications sector release of spectrum rights for the provision plays an important role in the Irish economy of wireless broadband (both mobile and fixed and accounts for around 17,000 full time broadband) services.1 equivalent jobs, €4 billion Gross Value Added and an estimated total contribution This spectrum management strategy of spectrum-dependant activities of €6.2 statement is an important tool for ensuring billion – amounting to 3.5% of Irish Gross the efficient use of spectrum. The National Income. consultation process was an opportunity for stakeholders to help shape our priorities, Communications services need clear channels particularly about the timing of future in order to carry out their operations. For assignment processes for different bands. We uses connected to public safety, this can be received many responses – for which we are critical to protecting property, health and grateful – and have carefully considered them human life. ComReg acts within our legislative in finalising our strategy. framework and within the resources available to us in order to make spectrum available, This strategy statement sets out ComReg’s free of interference and in a properly work plan and priorities for the next two managed manner. years in relation to its role as Ireland’s spectrum manager and complements There is a fast pace of technological ComReg’s Electronic Communications change affecting the way radio spectrum is Strategy Statement.2 used. Hand-held devices and tablets have become the main way that people access I look forward to the challenges we will face communications services and on-line over the next two years as ComReg strives applications. The connectivity that supports to deliver on the objectives outlined in them includes both WiFi access to fixed this statement. networks as well as mobile broadband. There are increased expectations for connectivity – Commissioner Jeremy Godfrey and the need for more capacity, faster speeds and wider availability of connectivity looks set to continue. We can also foresee new uses that require new forms of connectivity. 5G and other wireless technologies will not only enable Radio Spectrum Management Strategy Statement 2019 – 2021 3
Introduction 4 Radio Spectrum Management Strategy Statement 2019 – 2021
Radio spectrum is a medium by which information may be transmitted wirelessly over distances ranging from a few metres to thousands of kilometres. It is a valuable national resource underpinning important economic, social and communications activities. 2.1 Background and Purpose the Earth’s environment. However, 3 In accordance with ComReg’s it is a finite natural resource with obligations under 2.1 The Commission for Communications competing uses and users and so section 31 of the Communications Regulation (“ComReg”) is the it must be managed effectively and Regulation Act 2002 (as statutory body responsible efficiently used. amended) for the regulation of the (“2002 Act”). electronic communications 2.3 To assist ComReg’s management of 4 https://www. comreg.ie/ (telecommunications, the radio spectrum, ComReg regularly publication/ electronic- radiocommunication and sets out and updates its strategy communications- broadcasting networks), postal and for same3 and is also reflective strategy- statement-2017- premium rate sectors in Ireland in of ComReg’s strategic intents as 2019-design- accordance with European Union set out in its 5 year Electronic version/ (“EU”) and Irish law. ComReg also Communications Strategy Statement.4 5 ComReg Document manages Ireland’s radio frequency ComReg’s draft radio spectrum 18/74 – https:// www.comreg. spectrum (“radio spectrum” management plan for 2019 to 2021 is ie/publication/ or “spectrum”) and national set out in ComReg Document 18/745 proposed- strategy-for- numbering resource. (“Consultation 18/74”) and ComReg’s managing-the- radio-spectrum- consideration of the responses 2019-2021/ 2.2 Radio spectrum is a medium by which received from interested parties 6 ComReg information may be transmitted to that consultation is set out in Document 18/117 – available at wirelessly over distances ranging ComReg Document 18/117.6 ComReg.ie from a few metres to thousands of kilometres. It is a valuable national 2.4 Published alongside this document resource underpinning important is a report from Frontier Economics economic, social and communications (“Frontier”) that estimates the activities. These include widely contribution that radio spectrum used services, such as mobile/ makes to the Irish economy. The fixed wireless communications report is entitled “The Economic and broadband, radio and TV Contribution of Radio Spectrum broadcasting, and the safe operation to Ireland” (Document 18/118a) of air and maritime transport. Radio (“Frontier Report”). spectrum is also fundamental in the day-to-day operation of the 2.5 This document sets out ComReg’s emergency services and defence final radio spectrum management forces and is a vital input to many strategy statement and work plan for other services including important the period 2019 to 2021. scientific applications, such as weather forecasting and monitoring Radio Spectrum Management Strategy Statement 2019 – 2021 5
Radio Spectrum Strategy Statement Factors informing ComReg’s draft radio spectrum management strategy statement ComReg’s Strategic Goals ComReg’s Legal Mandate Wireless Technological & Resourcing Capability Advancements & Stakeholder Demand The spectrum management work plan for •• the harmonisation status and 7 The extent to which 2019 to 2021 appropriate timing for release any of these of spectrum bands that are considerations may affect 2.6 ComReg manages its workload currently unassigned; ComReg’s prioritisation in a manner that attempts to is considered appropriately and pragmatically •• the potential to remove certain on a case-by- case basis. address the needs of a diverse restrictions (or “liberalise”) currently range of actual and potential placed on licences which may enable spectrum users. In that regard, more efficient use of spectrum, ComReg balances the numerous facilitate innovation and potentially considerations to establish a free up capacity which could be made prioritised work plan commensurate available for other uses; with its resources, including: •• the potential for including multiple •• the capacity within the existing radio spectrum bands in a single award spectrum bands to meet spectrum process where appropriate to achieve needs. Where capacity exists, it may ComReg’s statutory objectives be possible to meet this demand via and duties; the existing spectrum assignments or to award new assignments using •• the adoption of legislation (national existing authorisation processes; or European) which requires ComReg to take defined actions within a •• the timing of the expiry of existing set timeframe; rights of use and the requirement for an appropriate re-assignment •• the potential for market mechanisms process in light of factors such as end to address spectrum management user demand, harmonisation status, issues;7 and equipment availability and availability of related spectrum bands; •• other relevant considerations that may arise. •• the international harmonisation status of a spectrum band including any future harmonisation plans; 6 Radio Spectrum Management Strategy Statement 2019 – 2021
ComReg’s spectrum work plan also reflects its statutory functions, objectives and duties, including to promote competition, to contribute to the development of the internal market, to promote the interests of users and to ensure the efficient management and use of the radio frequency spectrum in Ireland. 2.7 The spectrum work plan for 2019 to 2021 2.2 Structure of this document outlines the spectrum activities that ComReg intends to carry out within this timeframe 2.9 The remainder of this document is structured and includes: as follows: •• advancement of its proposed multi-band •• Chapter 3: provides an introduction to Ireland’s award of spectrum rights for the provision of radio spectrum and the importance of managing wireless broadband (both mobile and fixed the radio spectrum in Ireland; broadband) services; •• Chapter 4: considers the factors informing •• assisting the Department of Communications, ComReg’s strategy for the period 2019 – 2021; Climate Action and Environment (“DCCAE”), RTÉ and 2rn as appropriate in facilitating the migration •• Chapter 5: sets out ComReg’s Radio Spectrum of digital terrestrial television (“DTT”) services work plan for the period 2019 – 2021; and from the 700 MHz band by 4 March 2020; •• Annexes: •• assisting the DCCAE in the transposition of the European Electronic Communications •• Annex 1: Summary of ComReg’s statutory Code (“EECC”), and implementing same as framework relevant to the management of appropriate; and the radio frequency spectrum in Ireland; •• promoting Test and Trial Ireland and the •• Annex 2: Spectrum designators. benefits of using Ireland as a location to test or trial wireless products and services in a real world environment. 2.8 ComReg’s spectrum work plan also reflects its statutory functions, objectives and duties, including to promote competition, to contribute to the development of the internal market, to promote the interests of users and to ensure the efficient management and use of the radio frequency spectrum in Ireland. Radio Spectrum Management Strategy Statement 2019 – 2021 7
The Framework for Spectrum Management in Ireland 8 Radio Spectrum Management Strategy Statement 2019 – 2021
3.1 Spectrum Policy and Management 3.4 In the context of radio spectrum used for ECN/ in Ireland ECS, one of ComReg’s primary objectives is to promote and create the conditions for effective 3.1.1 Spectrum Policy competition in the provision of ECN and ECS. In that regard, section 12(2)(a) of the 2002 3.1 A key role of the DCCAE is the development Act requires ComReg to take all reasonable of policies for the regulation and optimal use measures which are aimed at the promotion of of Ireland’s radio spectrum. Spectrum policy competition, including: is part of the national policy governing the telecommunications sector in Ireland, which •• ensuring that there is no distortion or also covers next generation broadband, restriction of competition in the electronic electronic communications services (“ECS”) communications sector; and international connectivity. The DCCAE also has the responsibility for developing •• encouraging efficient use and ensuring the national broadcasting policy and associated effective management of radio frequencies and spectrum use. numbering resources; and 3.1.2 Spectrum Management: ComReg’s •• ensuring that users, including disabled users, mandate and role derive maximum benefit in terms of choice, price and quality. 3.2 The Communications Regulation Act 2002 (as amended) (the “2002 Act”), the European 3.5 Readers are referred to Annex 1 for an overview Common Regulatory Framework for electronic of the legal framework and statutory objectives communications networks (“ECN”) and ECS relevant to ComReg’s management of the radio (including the Framework and Authorisation spectrum. ComReg, in preparing the strategy Directives9 as transposed into Irish law by the set out herein, has also had regard to the corresponding Framework and Authorisation European Electronic Communications Code, a Regulations10), and the Wireless Telegraphy new EU Directive published in the EU Official Act 1926 (as amended)11 (the “1926 Act”) set Journal on 17 December 2018 and entering into out, among other things, functions, objectives, force on 20 December 2018, from which date powers and duties that are relevant to ComReg’s each Member State has two years to complete management of the radio spectrum. its transposition into national law. 3.3 In exercising its function of the management 3.6 ComReg recognises that the current European of Ireland’s radio spectrum (and in accordance Common Regulatory Framework for ECN and with relevant ministerial Policy Directions given ECS will be superseded by the EECC during under section 13 of the 2002 Act), ComReg’s the course of this forthcoming strategy primary spectrum management objective is to period. Among other things, the ECCC will ensure the efficient management and use of the consolidate, update and replace the various radio spectrum. ComReg is obliged to effectively directives under the existing framework (i.e. carry out this function, including having regard the Framework, Authorisation, Access and to relevant government policy statements and Universal Service directives). international developments. 9 Directive No. 2002/21/EC 10 European Communities 11 The Wireless Telegraphy (as amended by Regulation (Electronic Communications Acts, 1926 and 1956, the (EC) No. 717/2007, Regulation Networks and Services) Broadcasting Authority (EC) No. 544/2009 and (Framework) Regulations Acts, 1960 to 1971, in so far Directive 2009/140/ 2011 (S.I. No. 333 of 2011) as they amend those Acts, EC) (the “Framework (“Framework Regulations”) the Wireless Telegraphy Act Directive”) and Directive No. and the European 1972, Sections 2, 9, 10, 11, 12, 2002/20/EC (as amended Communities (Electronic 14, 15, 16, 17 and 19 of the by Directive 2009/140/ Communications Networks Broadcasting and Wireless EC) (the “Authorisation and Services) (Authorisation) Telegraphy Act 1988 and Directive”). Noting that Regulations 2011 (S.I. No. Sections 181 (1) to (7) and these directives are being 335 of 2011) (“Authorisation (9) and Section 182 of the replaced by the EECC. Regulations”). Noting Broadcasting Act 2009. that these regulations will be replaced by the Irish legislation that will transpose the EECC. Radio Spectrum Management Strategy Statement 2019 – 2021 9
It is estimated that the economic contribution of the radio spectrum to Ireland is a Gross Value Added of €4 billion and around €6.2 billion contribution to Irish Gross National Income 3.7 In fulfilling its spectrum management demand for the radio spectrum 12 The radio spectrum needs function, ComReg carries out a requires that it be used efficiently and be managed range of programmatic activities, that effective spectrum management because two or more radio including the: processes be employed to maximise signals occurring simultaneously the benefits to society. and in the same •• licensing of spectrum rights of use in location can interfere with Ireland for a wide variety of uses; 3.10 The ability to take full advantage of each other reducing the the spectrum resource depends on ability of the •• monitoring of radio spectrum usage the spectrum management activities radio spectrum to operate in Ireland, including the enforcement that facilitates the implementation effectively. It is not possible of licence conditions and equipment of radio systems with minimum radio for users to standards; and interference.12 However, as spectrum share spectrum indiscriminately is a finite resource with many because one user may cause •• promotion of Ireland as an ideal different actual and potential services interference for location for spectrum development and users, spectrum management another user. using Test and Trial Ireland. involves the careful consideration of a broad range of factors (e.g. 3.8 Further details of these activities are administrative, regulatory, social, set out in Chapter 4. economic and technical) with a view to ensuring that radio spectrum is 3.2 Spectrum Management efficiently used. This may also involve balancing a range of competing 3.9 The radio spectrum is a limited factors, including: and valuable national resource that permeates all areas of •• appropriately meeting the reasonable communications, including radio, requirements of all radio services, television, mobile voice and data, including commercial and public aeronautical/marine navigation, and uses, the latter including public safety, satellite communications. Increased national security and health care; and 10 Radio Spectrum Management Strategy Statement 2019 – 2021
Figure 1: Contribution of Radio Spectrum to GNI: 2013 – 2016 €6,500 €6,218 4.00% €5,576 €5,500 €3.54% 3.50% €3.46% €4,500 €4,329 (millions) €3,500 €3,441 €2.91% 3.00% €2,500 €2.51% 2.50% €1,500 €500 2.00% % of modified GNI Total contribution •• for spectrum used for ECS and ECN, of radio spectrum to Ireland. This 13 A significant part of the income promoting competition including analysis, which is based on company arising from ensuring that users derive maximum financial records and data from the the production of goods and benefit in terms of price, choice national accounts, conservatively services in Ireland accrues and quality, contributing to the estimates Gross Value Added (“GVA”) to the foreign development of the internal market, of €4 billion and around €6.2 billion owners of capital assets and promoting the interests of users contribution to Irish Gross National based in Ireland. Hence, the within the Community. Income (“GNI”)13 or approximately GDP aggregate 3.5% of GNI*. overstates the living standards 3.11 A system of spectrum management of Irish residents Modified GNI is required to ensure the efficient 3.13 Figure 1 illustrates the relationship is an indicator assignment and subsequent use of between Ireland’s GNI in years 2013 that was recommended scarce frequencies among competing to 2016 with the aggregate estimated by the Economic Statistics uses and users. This should promote economic contribution from the use of Review Group competition within the relevant radio spectrum over the same period. and is designed to exclude downstream markets, particularly It highlights that the contribution of globalisation effects that are given that spectrum is an essential radio spectrum increased from €3.4bn disproportionally input in the provision of many ECS and in 2013 to €6.2bn in 2016, accounting impacting the measurement of an inefficient assignment of spectrum for around 3.5% of GNI, when the size of the Irish economy. has the potential to distort/restrict modest multiplier effects are taken competition and create inefficient into account.14 14 In 2016, €4 billion is the direct outcomes for society. contribution, €1.3 billion is 3.14 Radio spectrum is also an important indirect with the 3.2.1 The importance of the radio contributor to employment. A remaining €0.98 million accruing spectrum conservative estimate of the number from taxes and subsidies. of employees in Ireland whose jobs are 3.12 Frontier Economics (‘Frontier’) directly dependent on the use of radio was commissioned by ComReg to spectrum was around 17,000 (FTE) estimate the economic contribution for 2016. Radio Spectrum Management Strategy Statement 2019 – 2021 11
Figure 2: The wireless day: how we use spectrum throughout the day Wake up, use the home Wi-Fi Drive to work: use a car Network on mobile and wireless “key” to unlock and laptop devices. deactivate the car alarm, or use the remote control to open the garage 07:00 09:00 Lunchtime shopping: pay The drive home: navigation by tapping cash card or on a mobile handset mobile handset with Near enabled by GPS Field Communication (NFC) 12:00 17:00 Evening at home: remote At night: baby alarms and control for TV Bluetooth other household sensors speakers and other accessories around the home 19:00 00:00
Social and secondary benefits of spectrum •• logistics – which uses wireless 15 Frontier define productivity usage technologies to enable more efficient (Total Factor supply chains and enhanced Productivity) as the output 3.15 There are also considerable social customer value. produced in an economy benefits arising from the use of radio for a given set spectrum. For example, the efficient Productivity enhancements of inputs used in production functioning of the Gardaí, fire and (capital and labour). ambulance services depends on 3.18 The use of radio spectrum, through reliable mobile communications, its ability to facilitate the deployment while radio spectrum plays a of new technologies and innovation, major role in enabling the Defence also positively contributes to Forces to carry out their duties improvements in productivity.15 both at home and overseas. Radio Investment in ICT capital used in the spectrum is also fundamental to Irish economy as a result of spectrum the safe operation of air, sea and is likely to contribute to productivity land transport and Ireland plays growth across a range of sectors and a particularly important role in lead to additional growth across the managing international radio traffic economy. Frontier conservatively in the aeronautical sector, dealing estimate that spectrum-related with all civilian flights between ICT investments have enhanced Europe and North America. productivity by around €0.5 billion in 2016 (see Chapter 3 of Frontier Report 3.16 Access to sufficient spectrum is – Document 18/118a). necessary in facilitating free-to-air television and radio broadcasting by 3.2.2 Spectrum management the public service and independent processes broadcasters. Effective free-to-air delivery of national and regional International aspects to spectrum broadcast schedules helps ensures management media plurality, a greater expression of national and community cultural 3.19 As radio frequencies naturally extend identity and the development of beyond national borders, spectrum home-grown audio-visual content, management requires knowledge including drama and documentaries. of, and involvement in, European Radio spectrum also enables the and global spectrum management use of a wide variety of consumer developments. Much of the radio applications improving the daily lives spectrum requires international of citizens. planning and in some cases this may constrain how specific frequencies or 3.17 Business applications are also likely frequency bands may be used. This to be enabled through the use of the is particularly so in the aeronautical radio spectrum across a variety of and maritime sectors where, because sectors, including: of the global nature of these services, ships and aircraft must use •• utilities – which uses wireless specific frequencies for navigation technologies to properly monitor and and communication purposes. The measure activity, and provide security frequency bands used by TV and in a widely distributed set of network radio broadcasting services have also assets. In the future, Smart Grids been harmonised for many decades will connect many more devices and to facilitate coordination between equipment to electricity networks; neighbouring countries and to assist the development of consumer •• agriculture – which uses wireless markets. More recently, an increasing applications to measure various number of radio frequency bands have aspects of animal husbandry and been internationally harmonised for arable farming to improve yield and commercial radio systems, such as reduce costs; and wireless mobile communications. Radio Spectrum Management Strategy Statement 2019 – 2021 13
The “allocation” of radio spectrum means “the designation of a given frequency band for use by one or more types of radiocommunications services, where appropriate, under specified conditions” 3.20 While the “allocation” and/or “assignment” of 3.21 As the radio spectrum manager for Ireland, spectrum is a national function, the global ComReg is charged with the implementation of regulation of spectrum is primarily within the remit international treaties and obligations relating of the International Telecommunication Union to the use of radio spectrum in the State.16 (“ITU”), while European regulatory functions lie The implementation of these measures often with the EU and the European Conference of requires actions in relation to the allocation Postal and Telecommunications Administrations and/or assignment of radio spectrum as (“CEPT”). These bodies define the broad discussed below. framework within which all spectrum users must operate and, in some cases, these bodies develop 3.22 Along with the DCCAE, ComReg plays an harmonised decisions, recommendations, and active role in international fora to ensure approaches for the use of spectrum. Harmonised that, as far as possible, decisions relating to radio frequency bands provide considerable the international radio spectrum regulatory benefits in facilitating the development of framework accommodate Ireland’s specific international services, promoting economies of requirements. ComReg additionally participates scale with respect to the manufacture of radio in technical compatibility studies and in equipment (thereby lowering both the cost of the development of technical standards to deploying wireless networks and the cost of support more efficient and flexible use of the wireless devices for consumers), and minimising radio spectrum. the risk of interference between users. 16 The interference-free consequent convergence of The radio spectrum operation of radio- services and technologies, decisions of the EU (the EU/ communication systems the Radio Regulations are EC Decisions) are binding across international borders revised every three to four decisions on EU Member is achieved through the years at a World Radio- States. These decisions implementation of the communication Conference. are normally based on Radio Regulations (RRs) The last WRC was held in the relevant technical and Regional Agreements, November 2015 in Geneva harmonisation measures as and the efficient and timely outlined in the CEPT reports update of these instruments The radio spectrum decisions to the EC and are generally through the processes of the and recommendations of adopted subsequent to the World and Regional Radio- the CEPT (ECC Decisions prior adoption of a CEPT communication Conferences. and ECC Recommendations) ECC Decision. A list of EU The Radio Regulations are non-binding on national Decisions/Recommendations (RRs), which have the status administrations. The is maintained at https:// of an international inter- list of ECC Decisions/ ec.europa.eu/digital-agenda/ governmental treaty, provide Recommendations and their en/radio-spectrum-policy- a framework for the use of the implementation status for document-archive radio frequency spectrum and all CEPT countries, including satellite orbits. To keep pace Ireland, is maintained at with the fast development http://www.erodocdb.dk of technologies and the 14 Radio Spectrum Management Strategy Statement 2019 – 2021
The “assignment” of radio spectrum refers to the spectrum management activities that issues, and authorises the use of, rights of use of radio frequencies. The allocation of radio spectrum in Ireland developments, such as the adoption 17 European Communities of European harmonisation decisions (Electronic 3.23 The “allocation” of radio spectrum and recommendations for a particular Communications Networks means “the designation of a given radio frequency band or service. The and Services) (Framework) frequency band for use by one or current version was published in May Regulations 2011 more types of radiocommunications 201718 and a comprehensive update is (S.I. 333 of 2011). services, where appropriate, anticipated following the ITU WRC in 18 ComReg Document 17/34 - under specified conditions”.17 An 2019 (see Chapter 4 for further details Radio Frequency Plan for Ireland allocation identifies the services on WRC-19). — published that could potentially use a 3 May 2017. radio frequency band and is an The assignment of radio spectrum in Ireland 19 A spectrum assignment refers important activity in facilitating to the rights of the international coordination of 3.26 The “assignment” of radio use for specific radio frequencies radio spectrum between regional spectrum refers to the spectrum within a frequency band areas and neighbouring countries management activities that issues, issued to an (thereby reducing the potential for and authorises the use of, rights of individual or for a station interference) and enabling economies use of radio frequencies.19 In Ireland, and usually under specified of scale. the possession and use of radio conditions (e.g. equipment requires authorisation in the context of radio frequencies 3.24 Under the 2002 Act, ComReg is from ComReg and this authorisation for ECS, one or more of the obliged to publish a Radio Frequency may take the form of a licence or a conditions Plan (“Plan”). The Plan is comprised licence-exemption under the 1926 Act. identified in Part B of the of a set of tables which sets out Schedule to the Authorisation Ireland’s radio spectrum allocations 3.27 Ideally, spectrum should be Regulations). for 8.3 kilohertz to 3000 Gigahertz, distributed efficiently, which means indicating the services to which giving access to the combination each frequency band is allocated of uses and users that maximises (“frequency allocations”) in the economic activity, subject to taking radio spectrum and is an essential account of social welfare, public and tool for current and future users of other legitimate policy concerns. radio frequencies. Granting spectrum rights of use to one user rather than another can 3.25 The Plan is updated regularly in line greatly impact the extent to which the with the outcomes of the ITU World radio spectrum is efficiently used to Radiocommunication Conferences deliver overall benefits for society. (“WRCs”) and other relevant Radio Spectrum Management Strategy Statement 2019 – 2021 15
3.2.3 Promotion of effective competition in 3.31 Goal 5 in turn reflects one of ComReg’s primary management of spectrum for ECS and objectives in respect of ECN and ECS being spectrum management tools the promotion of competition. The promotion of competition is a primary goal of ComReg’s 3.28 As noted above, spectrum is an essential spectrum management function because input in the provision of ECS and inefficient effective competition between wireless assignments of spectrum rights has the service providers brings long term benefits to potential to distort competition and create consumers in terms of price, choice, quality inefficient outcomes for society. of services and innovation. The efficient assignment and use of the radio spectrum 3.29 These issues are reflected in ComReg’s is therefore an important consideration in Electronic Communications Strategy promoting effective competition.22 Statement20 where the following three principle methods are identified by which to promote 3.32 In that regard, ComReg takes a proactive competition and consumer choice: approach to ensuring the efficient assignment and use of the radio spectrum while promoting 1. market access; effective competition and producing an 2. access to essential inputs; and optimal outcome for society. ComReg has a 3. demand-side factors. number of spectrum management tools that are designed to serve the interests of all users 3.30 In relation to the second principle (i.e. access of the radio frequency spectrum and strike to essential inputs), ComReg outlined its the right balance between those users while strategy to ensure that the management of the ensuring that spectrum is used efficiently and national spectrum (and numbering) resources competition is not distorted. ComReg uses take account of the promotion of competition, these tools as required, depending on the and the potential impact that the assignment circumstances of each particular assignment, in and allocation of these inputs may have on order to derive the maximum benefit for society downstream markets.21 This principle also informs and contribute to the development of the Goal 5 of the Electronic Communications Strategy internal market, while promoting the interests Statement, which requires ComReg to take all of users within the Community. These tools are reasonable measures which are aimed at the illustrated in Figure 3. promotion of competition. 3.33 The use of these tools involves the careful GOAL 5 consideration of a broad range of factors (e.g. administrative, regulatory, social, economic Spectrum management for and technical) with a view to ensuring that radio spectrum is efficiently assigned and electronic communications used. Any measures must also be objectively markets takes account, inter alia, justified, transparent, non-discriminatory and proportionate in relation to their of the promotion of competition. intended purpose. The use of such spectrum management tools often requires detailed Source: Electronic Communications Strategy Statement consideration with relevant stakeholders.23 2017–2019 20 ComReg Electronic 22 Article 8 of the Framework 23 See Goal 24 Electronic Communications Strategy Directive identifies Communications Strategy Statement 2017-2019: “encouraging efficient Statement below. “We are https://www.comreg.ie/ use and ensuring the proactive on engagement with publication/electronic- effective management of a range of stakeholders.” communications-strategy- radio frequencies (and statement-2017-2019- numbering resources)” as design-version/ a sub-objective of the broader objective of the 21 ComReg’s Electronic promotion of competition. Communications Strategy Statement 2017-2019 – p10. 16 Radio Spectrum Management Strategy Statement 2019 – 2021
Figure 3: Spectrum Management Tools Transition Caps Licensing License Duration License Conditions Spectrum Pricing Transfers Spectrum Auctions Compliance Coverage & Rollout
Spectrum management can facilitate 24 See Strategic Intention 3 Electronic investment by fostering regulatory Communications Strategy Statement “Efficient certainty and ensuring the availability of the investment has enabled affordable, high necessary inputs by effectively managing quality and widespread access to the radio spectrum. communications services and applications” 25 For example: the 700 MHz, 800 MHz or 900 MHz bands. 3.34 In its Electronic Communications GOAL 15 Strategy Statement, ComReg also noted, among other things that: The management of •• Creating the conditions for spectrum and numbers investment is as much about regulatory certainty as it is about facilitates efficient shaping operator incentives; investment. •• It will continue to publish its forward- Source: Electronic Communications Strategy looking strategy for managing the Statement 2017–2019 radio spectrum; and 3.36 In relation to bullets 2 and 3, the Radio •• It publishes information on existing Spectrum Management Strategy licensees’ spectrum assignments Statement is an important spectrum and related information and usage management tool of itself as it provides because, among other things, this interested parties with visibility of can increase the efficient use of future planned releases of spectrum, spectrum by better informing which allows them in turn to plan for consumers and other interested their spectrum needs. It also allows parties (such as actual and potential ComReg to take due account of the spectrum users). timing of each spectrum award. The assignment of harmonised bands, 3.35 In relation to the first bullet, such as those suitable for widespread spectrum management can coverage,25 provides opportunities for facilitate investment by fostering promoting new entry and competition. regulatory certainty and ensuring Given that rights of use for important the availability of the necessary bands are typically assigned for long inputs by effectively managing periods (e.g. 15 years, or potentially 20 the radio spectrum. In that regard, years as identified in the EECC), the effective competition is the principal timing of spectrum awards should be driver of efficient investment and as such that opportunities for promoting such ComReg seeks to create the new entry and effective competition conditions for investment primarily are maximised (e.g. ensuring that a mix by promoting competition. This is in of complementary and/or substitutable line with Goal 15 and ComReg’s ‘Third spectrum across different bands are Strategic Intention’.24 available at different intervals). 18 Radio Spectrum Management Strategy Statement 2019 – 2021
Modern environmentally friendly building materials reduces in‑door mobile coverage Modern insulation means that heat is kept in and houses are insulated from the cold… However, these materials also prevent radio waves from penetrating.
3.37 ComReg is also conscious of the need •• 2017 Ireland Communicates Survey 26 ComReg Document 18/35 to respond to changing circumstances of ICT usage by SMEs (Document – Mobile Data which could undermine efficiency and 18/23b); and Traffic Forecast in Ireland innovation and, in that regard, continues 27 ComReg to monitor the market in order to learn •• Mobile data usage forecasts Document 17/100a - Ireland from users’ ongoing experience and (Document 18/35 and 18/35a). Communicates adapt to changes in, among other Survey 2017 – Consumer - things, technologies, and demand for 3.40 For example, the following factors slides 43 & 46. services from spectrum users and have particularly important spectrum 28 ComReg end-users, market developments and management implications: Document 18/32a - Ireland relevant public policy. Communicates Survey 2017 •• Total annual mobile data traffic is – Consumer - Consumer information and market forecast to increase by over 3.5 times slide 51. monitoring between 2017–202226; 29 ComReg Document 18/32a - Ireland 3.38 As part of its spectrum management •• The Mobile Consumer Experience Communicates Survey 2017 function, ComReg also monitors Survey highlighted a number of key – Consumer - slides 54 & 56. the changes to the market since its issues and concerns with regard to 30 ComReg previous radio spectrum management mobile connectivity including: Document strategy statements and spectrum 18/32a - Ireland Communicates awards. ComReg is conscious that •• inside the home is where Survey 2017 – Consumer - the circumstances previously present consumers mostly use their mobile slide 32. may have changed or the market has phone for voice and data services27; 31 ComReg developed such that the spectrum Document 18/60 – Proposed management tools referred to above •• incidence of experiencing service multi band may need to be deployed differently issues in the house for calls/text spectrum award - preliminary to promote competition and protect and data (c. 30%) is higher than consultation on which bands consumers. This approach is in the same service issues that occur to award. line with Goal 8 of the Electronic outside the home28; 32 ComReg Communications Strategy Statement. Document 18/103c - https:// •• rural consumers have higher rates www.comreg. GOAL 8 of experiencing service issues ie/publication/ future-mobile- regardless of location with higher connectivity- ComReg understands levels of service issues arising in in-ireland/ the home (i.e. indoor)29; evolving consumer needs, preferences, behaviours •• The ICT survey highlighted that making and receiving calls and perceptions. domestically remains the most important use of mobile telephony. Source: Electronic Communications Strategy Statement 2017 – 2019 3.41 In response to the information received, ComReg initiated the following work 3.39 In that regard, ComReg continually streams with a view to informing future tracks end-user usage trends (see spectrum award proposals, providing ComReg Quarterly Reports) and has additional consumer information and completed various market research improving the connectivity experience and forecasting in order to inform for consumers: future spectrum management activities. For example: •• Progressing its proposals for the release of spectrum rights for the •• B&A Mobile Consumer Experience provision of wireless broadband (both Survey (See Documents 17/100 and mobile and fixed broadband) services;31 17/100a); •• a Future Mobile Connectivity in Ireland •• 2017 Ireland Communicates Survey of (“FMC”) study to obtain advice on ICT usage by consumers (Document mobile connectivity services and the 18/23a); potential costs of providing same;32 20 Radio Spectrum Management Strategy Statement 2019 – 2021
•• “Meeting Consumer’s Connectivity GOAL 17 33 ComReg Document Needs” – a report for ComReg that Mobile coverage 18/103b - https:// provides an overview of the challenges www.comreg. ie/publication/ in providing connectivity in Ireland and the actions that all stakeholders obligations are used to meeting- consumers- connectivity- can take to optimise their levels of connectivity which are available on promote investment needs/ 34 ComReg different networks across Ireland;33 where proportionate. Document 18/103d - https:// www.comreg. ie/publication/ •• “Coverage obligations and Spectrum Source: Electronic Communications Strategy coverage- obligations- Awards” – a report for ComReg that Statement 2017–2019 and-spectrum- considers how and the extent to which awards/ coverage and rollout obligations can be 3.43 In providing for same, ComReg 35 ComReg Document 18/73 included in future spectrum awards;34 recognises the need to communicate – The effect of building material with different stakeholder groups and on indoor mobile •• Effect of Building Materials on Indoor interested parties. This engagement performance. Mobile Performance: determining and takes a number of forms, including 36 ComReg Document 18/26 reporting upon the extent to which formal consultation39 and publication – Assessment of some representative modern building of proposals on the ComReg mobile network operators’ materials impact on in-building website, and is in line with Goal 24 compliance with licence coverage by measuring overall of the Electronic Communications obligations attenuation through each building Strategy Statement. (coverage) winter 2017. material tested;35 37 ComReg GOAL 24 Documents •• Bi-Annual Drive Testing - 18/05 and 18/78 Assessment of Mobile Network We are proactive on - Mobile Handset Performance (Voice) & The Operators’ Compliance with Licence Obligations (Coverage);36 engagement with a range Effect of Building Materials on Indoor Mobile •• Mobile Handset Performance: of stakeholders. Performance. 38 ComReg Document 18/82 measuring and reporting on the - Mobile Handset antenna performance of mobile Source: Electronic Communications Strategy Performance (Data) handsets available on the Irish market Statement 2017–2019 39 ComReg in order to quantify the performance of Document 11/34 each handset when making or receiving 3.44 ComReg will publish the output - Consultation Procedures. a mobile call and to stream data. See: from each work stream and the information contained therein will be •• Voice (Document 18/05 and 18/78)37 used to inform ComReg’s spectrum management activities across a range •• Data (Document 18/82)38; and of projects in order to promote the best outcomes for society. •• Mobile Coverage Prediction Map - a solution to provide consumers with a visual (geographic-based) means of presenting predicted mobile coverage throughout Ireland, through the use of an interactive website. 3.42 This approach is also in line with Goal 17 of the Electronic Communications Strategy Statement. In particular, the FMC study and the Coverage Obligations and Spectrum Awards Report will be used by ComReg to inform its considerations regarding the appropriate coverage obligations that should be attached to, among other things, 700 MHz rights of use. Radio Spectrum Management Strategy Statement 2019 – 2021 21
Factors informing ComReg’s work plan for 2019 – 2021 22 Radio Spectrum Management Strategy Statement 2019 – 2021
4.1 A wide range of factors influence the 4.1 International harmonisation of 40 In Ireland, harmonised demand for and the supply of radio radio spectrum spectrum bands spectrum including: end-user demand, support a wide range of services, technology changes or advancements, 4.4 The international harmonisation include those provided by the international harmonisation of process plays a key role in determining mobile operators. radio spectrum, and relevant national the demand for and the supply of 41 For example, the or international policies. radio spectrum, given its benefits ECC CEPT work plan for 2018 to in terms of facilitating economies 2020 identifies the following 4.2 These general factors also influence of scale in the manufacture of radio major topics: each other. For example, increasing equipment (which lowers both the • Assess the end-user demand for a service cost of deploying wireless networks feasibility of M2M/IoT through incentivises advancements in and the cost of wireless devices for satellite from technologies used to provide these consumers), and the minimisation of a technical and regulatory services and the development of interference between users. point of view; • Spectrum international harmonisation measures for wireless or national/international policies, and 4.5 International harmonisation, and the broadband (including vice versa. benefits from same, is particularly 5G); and • The use of important for countries with a MFCN for UAS. 4.3 In this chapter, ComReg discusses small population, such as Ireland, 42 The draft RSPG various factors which have informed and, therefore, limited ability to work programme for 2018 and its radio spectrum work plan for 2019 affect the technology roadmaps beyond includes to 2021, including: adopted by often global suppliers of the following work items: radio equipment. • EECC; •• International harmonisation of • RSPG structure and working radio spectrum; 4.6 In ComReg’s experience, the methods; appropriate release of harmonised • Peer review and Member State •• World Radiocommunication spectrum bands has proven to be cooperation on authorisation Conference of 2019; generally very successful in facilitating and awards; the delivery of services to end-users.40 • 5G Implementation •• European Commission Challenges; • Common Policy harmonisation decisions; 4.7 Harmonised radio spectrum measures objectives are implemented by a number of for WRC-19; • “Good offices” to •• End-user demand (and, in particular, bodies including the ITU (and/or the assist in bilateral for mobile broadband); constituent regional groups), the negotiations between EU CEPT and relevant EU bodies. These countries; and • European •• Technology changes and bodies generally set a forward-looking Spectrum advancements (service specific); and work programme and this provides Strategy. an indication of future harmonisation •• The expiry of existing licences in the measures. For example, see the work near future (e.g. within the next 5 years). plans of CEPT41 and RSPG.42 In some Radio Spectrum Management Strategy Statement 2019 – 2021 23
In addition to the harmonisation of radio spectrum bands, the setting of harmonised radio equipment standards play a major facilitating role in spectrum management, particularly in terms of minimising the risk of interference between users. instances, harmonisation decisions 4.10 The major agenda items of interest 43 In Europe, EU/ EC decisions are obligatory on Member States to Ireland at WRC-19 are expected are obligatory thereby directly increasing the supply to be: on Member States, while of spectrum at a national level with a CEPT decisions are non-binding defined timeframe.43 •• Broadband applications in the Mobile and voluntarily Services - I. The following bands, adopted by its members. 4.8 In addition to the harmonisation of which are already allocated to Mobile radio spectrum bands, the setting of Services are being studied with a view harmonised radio equipment standards to an IMT-2020 identification: play a major facilitating role in spectrum management, particularly in terms a) 24.25 - 27.5 GHz; of minimising the risk of interference b) 37 - 40.5 GHz; between users. Within Europe, the main c) 42.5 - 43.5 GHz; stakeholders responsible for setting d) 45.5 - 47 GHz; these standards are the European e) 47.2 - 50.2 GHz; Committee for Standardisation f) 50.4 - 52.6 GHz; (“CEN”), the European Committee g) 66 - 76 GHz; and for Electrotechnical Standardisation h) 81 - 86 GHz; (“CENELEC”) and the European Telecommunications Standards •• Broadband applications in the Institute (“ETSI”). These bodies also Mobile Services – II. The following work alongside national technical bands will also be studied, although committees and various industry they do not currently have global bodies. For example, the Institute of mobile allocations: Electrical and Electronics Engineers (“IEEE”) and the WiMAX Forum. a) 31.8 - 33.4 GHz; b) 40.5 - 42.5 GHz; and 4.1.1 The World c) 47 - 47.2 GHz; Radiocommunication Conference of 2019 •• To take appropriate regulatory actions (which include additional 4.9 Led by the DCCAE, Irish preparations Mobile Service allocations) for for World Radiocommunications Wireless Access Services / Radio Conference 2019 (“WRC-19”) are LANs in the bands between 5 150 - 5 underway. ComReg is involved in 925 MHz; this work and will assist the DCCAE to meet objectives and goals that •• Studies to consider possible global will be established in the national or regional harmonised bands, to preparatory process. the maximum extent possible, 24 Radio Spectrum Management Strategy Statement 2019 – 2021
M2M Cellular IoT Technologies for implementation of evolving •• Studies on development of a regulatory 44 ECC Report 266 on the Suitability Intelligent Transport Systems framework for non-GSO FSS systems of the current (“ITS”) within existing Mobile that may operate in the bands 37.5-39.5 ECC Framework for the usage of Service allocations; GHz (s-E), 39.5-42.5 GHz (s-E), 47.2- Wideband and Narrowband M2M 50.2 GHz (E-s) and 50.4-51.4 GHz (E-s). in the frequency •• To consider possible regulatory bands 700 MHz, 800 MHz, actions to support Global Maritime 4.11 The outcome of WRC-19 will influence 900 MHz, 1800 MHz, 2.1 GHz Distress and Safety Systems the future work plans of the relevant and 2.6 GHz. (“GMDSS”) modernisation and the bodies of the EC and CEPT and introduction of additional satellite consequently ComReg. systems into GMDSS; 4.2 European Commission •• Studies to consider regulatory harmonisation decisions actions within the band 156 - 162.05 MHz for autonomous maritime 4.2.1 Existing EC harmonisation radio devices to protect GMDSS decisions and Automatic Identification System (“AIS”); M2M Cellular IoT Technologies •• To consider new Maritime-Mobile 4.12 Machine to Machine (“M2M”) Satellite Service (MMSS E-s and communication and the Internet of s-E) allocations, preferably within Things (“IoT”) are widely considered 156.0125 - 157.4375 MHz and 160.6125- to be applications with significant 162.0375 MHz to enable a new VHF growth potential. Among M2M/IoT data exchange system (“VDES”) technologies, some are designed satellite component; to operate in the spectrum bands assigned to MFCN. •• Studies to consider the spectrum needs and regulatory provisions 4.13 In this regard, ComReg would highlight for the introduction and use of the the following: Global Aeronautical Distress and Safety System (“GADSS”); •• in June 2017, CEPT published ECC Report 26644 which concluded •• To consider the use of the bands that certain M2M technologies (i.e. 17.7-19.7 GHz (s-E) and 27.5 29.5 LTE-MTC, LTE-eMTC, EC-GSM-IoT GHz (E-s) by earth stations in and NB-IoT) can co-exist with the motion communicating with GSO technologies currently deployed in space stations in the FSS and take certain frequency bands currently appropriate action; and harmonised for MFCN; Radio Spectrum Management Strategy Statement 2019 – 2021 25
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