WISPs want clarity on 3.6 Ghz allocation

clohamon · 26-03-2015 12:18pm #1

The submissions to ComReg's Call-for-Input on regulatory issues related to the National Broadband Plan (NBP) brought a lot of complaints from WISPs about being denied the certainty of spectrum availability which they need to invest in NGA services.

They believe ComReg has denied them the ability to defend their business interests from being extinguished by the NBP

Imagine believe they are a special case and have sought an executive order from ComReg to by-pass the normal allocation procedures.

http://www.comreg.ie/publications/national_broadband_plan__call_for_input_on_regulatory_implications_-_submissions.

watty · 26-03-2015 6:58pm

Imagine are a special case, but not in the way they like to imagine.

rob808 · 26-03-2015 7:29pm

Imagine are terrible company I was with them before they weren't great so cancel there broadband and pay what I own them they call me up 3 week later saying I own them more so pay them again never would deal with them again.

I hope comreg don't listen to them and they get no part in the NBP.

clohamon · 14-04-2015 10:46am

watty wrote: »

Imagine are a special case, but not in the way they like to imagine.

Their submission (47 pages) to the second Map consultation asserts favouritism towards wired solutions. They suggest that a biased process risks legal proceedings.

As a general view, it is clear that the Preliminary Views expressed herein demonstrate a clear bias in favour of wired technologies and an active bias against qualifying radio technologies

Any suggestion of discriminatory practice or non-conformity with the SAG conditions risks exposing DCENR to challenge, difficulty in securing approval from Brussels or funding. All of these pose a schedule risk to the NBP with associated negative impact on the Irish Economy.

clohamon · 17-06-2015 8:27pm

ComReg respond to submissions to call for input on NBP.

The timescale indicated would seem to leave the allocation of spectrum until after the forecast NBP tender window.

122 That being said, ComReg remains conscious of the expiry of existing 3.6 GHz licences in July 2017 and the request that clarity on the future of the 3.6 GHz band be provided as far as possible in advance of this date. Accordingly, it is ComReg’s current intention, noting the points made above, to issue its response to the 3.6 GHz consultation and further information on next steps by end of year.

http://www.comreg.ie/_fileupload/publications/ComReg1557.pdf

rob808 · 17-06-2015 8:32pm

clohamon wrote: »

ComReg respond to submissions to call for input on NBP.

The timescale indicated would seem to leave the allocation of spectrum until after the forecast NBP tender window.

http://www.comreg.ie/_fileupload/publications/ComReg1557.pdf

That most likely mean it mainly between Eircom and siro for the NBP.

oscarBravo · 17-06-2015 9:32pm

clohamon wrote: »

ComReg respond to submissions to call for input on NBP.

The timescale indicated would seem to leave the allocation of spectrum until after the forecast NBP tender window.

Meh. You can't build future-proofed broadband infrastructure on wireless anyway. If DCENR are serious about the goals of NBP, there won't be any wireless component to it.

clohamon · 18-06-2015 2:11pm

oscarBravo wrote: »

Meh. You can't build future-proofed broadband infrastructure on wireless anyway. If DCENR are serious about the goals of NBP, there won't be any wireless component to it.

Agree, but if they want to proof the NBP against legal attack they shouldn’t be playing hide and seek with the spectrum.

The Minister can just direct the use of specific bands. If he tells the Regulator to hold that band available for any wireless winner of the NBP it would probably satisfy everybody.

Better to specify what they actually want with performance criteria. eg 150Mb/s symmetric.

oscarBravo · 18-06-2015 2:25pm

clohamon wrote: »

The Minister can just direct the use of specific bands.

Can he? Isn't spectrum allocation ComReg's competence, and aren't they supposed to be independent?

If he tells the Regulator to hold that band available for any wireless winner of the NBP it would probably satisfy everybody.

If he does that, he's explicitly permitting wireless to be considered next-generation infrastructure. If the minister told ComReg to ringfence 3.6 for NBP and DCENR didn't allow for wireless to be used, the band would become unusable. If DCENR do allow for wireless, they'll be entrenching the digital divide instead of taking this last opportunity to get rid of it.

Better to specify what they actually want with performance criteria. eg 150Mb/s symmetric.

That would pretty much turn the whole map orange again. I don't see it happening.

If there's going to be a wireless component to NBP, it has to be explicitly short-range, explicitly fibre to a single wireless last-mile hop, and explicitly interim.

clohamon · 18-06-2015 2:55pm

oscarBravo wrote: »

Can he? Isn't spectrum allocation ComReg's competence, and aren't they supposed to be independent?

Section 13 Communications regulation Act 2002

(5) A direction under subsection (1) relating to management of the radio frequency spectrum may include directions relating to—
(a) the allocation of particular bands of spectrum for specific categories of service, and
(b) the means by which entitlements to use such spectrum may be assigned (including appropriate fees),
and in giving such direction the Minister shall have regard to principles of good frequency management.

oscarBravo wrote: »

If he does that, he's explicitly permitting wireless to be considered next-generation infrastructure.

He has to, and he has. Its in the State Aid Guidelines, but subjective criteria apply to the exact implementation of wireless solutions.

oscarBravo wrote: »

If the minister told ComReg to ringfence 3.6 for NBP and DCENR didn't allow for wireless to be used, the band would become unusable.

If no wireless provider won the tender, the band would revert to the Regulator for allocation as he sees fit.

oscarBravo wrote: »

If DCENR do allow for wireless, they'll be entrenching the digital divide instead of taking this last opportunity to get rid of it. That would pretty much turn the whole map orange again. I don't see it happening.

As far as I can see nearly all the blue bits are inside eircom's VDSL footprint. I don't quite know why they set the bar so low (30Mb/s). Maybe it's to do with funding from Europe.

oscarBravo wrote: »

If there's going to be a wireless component to NBP, it has to be explicitly short-range, explicitly fibre to a single wireless last-mile hop, and explicitly interim.

Agree, but nothing at all will be going on if it's held up in court because of perceived bias.

watty · 18-06-2015 4:29pm

clohamon wrote: »

As far as I can see nearly all the blue bits are inside eircom's VDSL footprint. I don't quite know why they set the bar so low (30Mb/s).

To extend the range that VDSL can be used to. Its speed drops very quickly indeed with distance.
But even 30 Mb/s isn't very far. 60Mb/s is maybe 1/4 the wire length.

Phone wire is not only only Cat3, compared to Cat5e usually used to get 100m 100Mbps, which uses separate pairs for TX and RX (1Gbps uses all four pairs, each at 250 Mb/s, and echo cancellation to do duplex) but also there is far more crosstalk if a fat multipair cable. So 100 Mbps VDSL barely does 100m in the real world. Unlike Cat5e, the Cat 3 cable was never intended for more than telephone quality voice.

clohamon · 21-06-2015 5:32pm

There's a piece in today’s The Sunday Business Post (paywall) quoting John McDonnell CEO of Ripplecom

[McDonnell] argued that the new service [govt 30Mb/s scheme] could be significantly more expensive than rural customers already pay and cast doubt on how quickly the plan would be rolled out

“Our view and the view of the people who are working in the market, is that with the geographic scale it’s more like an eight-year project than a three-year project”

“delivering fibre broadband as planned by the government is neither viable economically, nor is it necessary”

watty · 21-06-2015 7:12pm

Well, he would say that.
Much as I support and endorse Fixed wireless for Broadband*, it can only in the future be for one to a handful of isolated people per fibre fed mast. Fibre is actually cheaper. About 1/10th the infrastructure cost of real 30 Mbits wireless, but x10 speed minimum.

Wireless is now a last resort tech for a farm on a mountainside with no ESB.

(*In the past vs Mobile, which can't ever deliver Broadband except we had x10 or x20 as many masts, which won't happen. Why are they STILL allowed to subsidise data packages by voice and SMS and mis-sell it as Broadband?
Since about 2007 the company with best Fixed Wireless data has been investing in fibre and pretty much halted Wireless rollouts from end of 2008 and continued with Fibre acquisitions.)

funnyname · 21-06-2015 10:19pm

clohamon wrote: »

There's a piece in today’s The Sunday Business Post (paywall) quoting John McDonnell CEO of Ripplecom

Luddites

clohamon · 01-07-2015 2:45pm

It looks like 160 Mhz of the 3.6 Ghz band might be available for FWA after 2017.

This figure comes from taking the 360 MHz indicated to be available for use from ComReg doc 14/101 (para 3.29) and deducting the 200 Mhz assumed by Frontier Economics to be available for mobile use after 2017 (see ComReg 1562b para 2.1.3 Table 1).

Whether any of it will be available for regional use seems doubtful.

"However, for the purposes of this chapter 3, ComReg assumes that any rights of use in the 3.6 GHz band included in this award process will be made available on a national basis.” - ComReg 14/101 para 3.30

rob808 · 01-07-2015 9:36pm

clohamon wrote: »

It looks like 160 Mhz of the 3.6 Ghz band might be available for FWA after 2017.

This figure comes from taking the 360 MHz indicated to be available for use from ComReg doc 14/101 (para 3.29) and deducting the 200 Mhz assumed by Frontier Economics to be available for mobile use after 2017 (see ComReg 1562b para 2.1.3 Table 1).

Whether any of it will be available for regional use seems doubtful.

That good couldn't see FWA being able to give 30mb at all times of day and looking at ripplecom broadband the price it is and download allowance being so small won't like them to win the tender.

ItHurtsWhenIP · 02-07-2015 9:35am

rob808 wrote: »

That good couldn't see FWA being able to give 30mb at all times of day and looking at ripplecom broadband the price it is and download allowance being so small won't like them to win the tender.

That got me thinking - does the NBP have any stipulation around data allowances?

clohamon · 02-07-2015 10:37am

MMFITWGDV wrote: »

That got me thinking - does the NBP have any stipulation around data allowances?

No, though there is a final DCENR consultation due this month (July)

The questions put so far are mostly about the capability of the infrastructure, not the retail package that one might chose to buy.

clohamon · 02-07-2015 10:44am

MMFITWGDV wrote: »

That got me thinking - does the NBP have any stipulation around data allowances?

No, though there is a final DCENR consultation due this month.

The questions discussed so far are mostly about the capability of the infrastructure, not the retail package that one might chose to buy.

The current USO does not cover broadband or data allowances and is unlikely to change before 2020.

rob808 · 02-07-2015 10:57am

clohamon wrote: »

No, though there is a final DCENR consultation due this month.

The questions discussed so far are mostly about the capability of the infrastructure, not the retail package that one might chose to buy.

The current USO does not cover broadband or data allowances and is unlikely to change before 2020.

This why I hope Eircom win the tender at least it be a open network plus it be future proof with FTTH and with some people getting LTE with fibre to the mast so they would be following EU rule not using one technology.

clohamon · 14-07-2015 12:43pm

ComReg has set out its preferred conditions in this doc. Respondents have until 7th August 2015 to reply. After that Comreg will publish the draft licences and the auction will take place before the end of the year. Summary below. The underlying assumption is that interested parties will be FWA providers.

Allocation: 350 Mhz in 9 areas
Band Plan: TDD
Licence duration: 15 years
Allocation type: Combinatorial Clock Auction.
Spectrum cap: 150 - 250 Mhz (Max per licence)
Blocksize: 65 x 5 Mhz blocks and 1 x 25 Mhz block

Areas: separated into 9 areas with stated populations (adjusted for commuting).

Five Cities and their suburbs: Dublin, Cork, Galway, Limerick and Waterfrd
North West: Counties Donegal, Leitrim, Sligo, Mayo, Roscommon and Galway excluding the Galway CSO City and Suburb region.
North East: Counties Cavan, Monaghan, Louth, Longford, Westmeath, Meath, Offaly, Laois, Kildare, Wicklow and Dublin excluding Dublin CSO City and Suburb region.
South East: Counties Kilkenny, Carlow, Wexford, the legal boundary of South Tipperary and Waterford, excluding Waterford City and Suburbs
South West: Counties, Clare, Limerick excluding Limerick CSO City and Suburbs, Kerry and Cork excluding Cork CSO city and Suburbs and the legal boundary for North Tipperary.

Minimum Price: €0.015 - € 0.025 /Mhz/cap (lower price for rural areas, higher for cities)*
SAF/SUF split: 50/50
Technology: Neutral but min throughput of 4bps/Hz required (suggested LTE-A)
Coverage: (proposed)

Minimum number of base stations required to deploy in a licence area. (having regard to current deployment and necessary spread of deployment)
4 non-urban regions: 15 to 25. (Min 3-5 counties to be covered within a region)
Urban areas (excl Dublin): 2 to 4
Dublin: 15-25
Base stations may be mandated in a number of distinct areas within the licensed area.

Roll-out: 3-5 years starting 1/08/2017
QOS: as for Mobiles. MBSA licence conditions will apply if a voice service is to be delivered.

http://www.comreg.ie/_fileupload/publications/ComReg1570.pdf

watty · 14-07-2015 6:21pm

Idiotic

rob808 · 14-07-2015 8:41pm

clohamon wrote: »

ComReg has set out its preferred conditions in this doc. Respondents have until 7th August 2015 to reply. After that Comreg will publish the draft licences and the auction will take place before the end of the year. Summary below. The underlying assumption is that interested parties will be FWA providers.

Allocation: 350 Mhz in 9 areas
Band Plan: TDD
Licence duration: 15 years
Allocation type: Combinatorial Clock Auction.
Spectrum cap: 150 - 250 Mhz (Max per licence)
Blocksize: 65 x 5 Mhz blocks and 1 x 25 Mhz block

Areas: separated into 9 areas with stated populations (adjusted for commuting).
Five Cities and their suburbs: Dublin, Cork, Galway, Limerick and Waterfrd

North West: Counties Donegal, Leitrim, Sligo, Mayo, Roscommon and Galway excluding the Galway CSO City and Suburb region.

North East: Counties Cavan, Monaghan, Louth, Longford, Westmeath, Meath, Offaly, Laois, Kildare, Wicklow and Dublin excluding Dublin CSO City and Suburb region.

South East: Counties Kilkenny, Carlow, Wexford, the legal boundary of South Tipperary and Waterford, excluding Waterford City and Suburbs

South West: Counties, Clare, Limerick excluding Limerick CSO City and Suburbs, Kerry and Cork excluding Cork CSO city and Suburbs and the legal boundary for North Tipperary.

Minimum Price: €0.015 - € 0.025 /Mhz/cap (lower price for rural areas, higher for cities)*
SAF/SUF split: 50/50
Technology: Neutral but min throughput of 4bps/Hz required (suggested LTE-A)
Coverage: (proposed)
Minimum number of base stations required to deploy in a licence area. (having regard to current deployment and necessary spread of deployment)
4 non-urban regions: 15 to 25. (Min 3-5 counties to be covered within a region)
Urban areas (excl Dublin): 2 to 4
Dublin: 15-25
Base stations may be mandated in a number of distinct areas within the licensed area.

Roll-out: 3-5 years starting 1/08/2017
QOS: as for Mobiles. MBSA licence conditions will apply if a voice service is to be delivered.

http://www.comreg.ie/_fileupload/publications/ComReg1570.pdf

What the realistic speed will wisp be able to deliver with 3.6Ghz.

clohamon · 15-07-2015 12:19pm

The coverage analysis is done in this doc.
http://www.comreg.ie/_fileupload/publications/ComReg1575.pdf

There’s lots of scenarios but just taking rural Donegal (excluding Letterkeny, Donegal Town and Buncrana.) Total population 47,000. Households 17,000. Area 4860 kmsq

Case 1:
All households having access to un-contended 30Mb/s:
Base stations needed: 294
Spectrum needed: 300 Mhz (ie nearly all of the allocation)

Case 2:
4% of households having access to 30Mb/s at 8:1 contention
Base stations needed: 6
Spectrum needed: 60Mhz

Case 3:
50% of households having access to 30Mb/s at 8:1 contention
Base stations needed: 56
Spectrum Needed: 100 Mhz

NB:
Fibre backhaul issues are not considered
Line of Sight issues are not considered at all in case 1 and 2.

The doc appears to suggest that Case 3 is do-able because an existing Mobile would be able to, do it itself or, make its base stations available to a WISP. Additionally the 50% take-up was seen as possible because broadband is otherwise so bad in Donegal at the moment.

However the option of just doing rural Donegal doesn’t seem to be available. Instead a WISP would have to purchase a licence for “the North West”, pay the price for the entire region and then build a business case on the basis of wildly different demographics and markets within the region.

The minimum cost for "the North West" using 100Mhz for 15 years would be 100Mhz x 608,768 (pop) x €0.015/Mhz/pop (SAF+SUF) = €913,152

So its seems 30Mb/s is technically possible but given the structure of the licenses it’s not likely.

watty · 15-07-2015 1:46pm

Those numbers of bases vs spectrum vs capacity don't sound quite right. But I haven't done the sums. It depends too on the Subscriber's aerial gain.

You also have to consider terrain, which usually means more base stations needed.

clohamon · 15-07-2015 1:49pm

watty wrote: »

Those numbers of bases vs spectrum vs capacity don't sound right.

Have a look at the doc. Its not very long.
http://www.comreg.ie/_fileupload/publications/ComReg1575.pdf

bk · 16-07-2015 10:23am

The question here would be how much each base station would cost?

I've heard a rough estimate that a LTE site (including planning, site rental, gear, electricity, etc.) costs about €150,000

So you are looking at:
150000 × 56 = €8.4 million

To put that in perspective that would be about €1000 per house serviced.

You would be well on your way to serving most of those homes with FTTH for €1000 per home, especially when you consider the much lower ongoing operating and maintenance costs.

clohamon · 16-07-2015 10:33am

bk wrote: »

The question here would be how much each base station would cost?

I think the inference is that a WISP would install its gear on an existing MNO tower network and just pay rent. Or alternatively an MNO would bid for the spectrum and install the FWA gear on its own towers.

bk · 16-07-2015 10:56am

clohamon wrote: »

I think the inference is that a WISP would install its gear on an existing MNO tower network and just pay rent. Or alternatively an MNO would bid for the spectrum and install the FWA gear on its own towers.

But are there 56 LTE towers in Donegal? There certainly isn't 294

And even at that, you still would have high ongoing property rental and electricity costs.

bk · 16-07-2015 11:04am

bk wrote: »

But are there 56 LTE towers in Donegal? There certainly isn't 294

And even at that, you still would have high ongoing property rental and electricity costs.

Answering my own question. According to the Comreg site there seems to be roughly 284 total in Donegal amongst all operators.

Though many seem to be GSM only (so no fiber backhaul at the moment) and many also seem to have all three operators on one site.

So I'd guess there are roughly 100 unique sites.

clohamon · 16-07-2015 11:24am

bk wrote: »

But are there 56 LTE towers in Donegal? There certainly isn't 294

And even at that, you still would have high ongoing property rental and electricity costs.

This is from the consultant's report

ComReg‟s Siteviewer tool indicates a total of 224 mobile base stations in rural Donegal, equivalent to 56 per operator. Since it is likely that mobile infrastructure is more coverage than capacity driven in such a sparsely populated area, this suggests that a fixed wireless network configured to deliver coverage to all of the populated areas of Donegal, having access to 100 MHz of spectrum and sufficient fibre backhaul capacity would be capable of serving up to half the population with a high speed broadband service.

On the actual business case, we'd probably need to hear from a WISP. ComReg don't usually leave much money on the table.

WISPs want clarity on 3.6 Ghz allocation

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