Jesus Loves Comreg

Sponge Bob

Consultation Responses on Radio Spectrum, it is

http://www.comreg.ie/_fileupload/publications/ComReg0536.pdf

Response to the Consultation on a Strategy
for Management of the Radio Spectrum. 2005 - 2007

indeed, and look at the respondents

The thirty five respondents to the consultation were, in alphabetical order:
• Abundant Life Church
• Anne Newell
• Brian Duffield
• Carol MacGuinness
• Centre for Justice & Liberty
• Chorus
• Chris Bower
• Competition Authority
• eircom
• Esat
• ESB Telecom
• Evangelical Alliance Ireland
• Focus on the Family Ireland
• Forfás
• Futurepace Solutions
• Gary Hill
• Gerard Shanahan
• Intel Corporation
• Irish Christian Broadcasters
• JP Walsh
• Kevin Fitzgibbon
• Met Éireann
• Mona Evans
• ntl
• Oak Global
• O2
• Paddy Monaghan
• Peter Finch
• Roisín Ní Cheallaigh
• Scagaire
• Sean Dooley
• Three
• Tom MacGuinness
• TV3
• Vodafone

WTF is this then ????

ComReg is proposing to permit Wireless Public Address Systems in the band 27.6 – 27.99 MHz to meet the needs of religious and other community organisations.

Indeed , how nice.

There was considerable interest and comment by more than half the respondents to the consultation on the topic of wireless public address systems

What is in store for us in here?

ComReg has participated actively in the discussions at the European level on the regulatory and technical measures to be implemented to facilitate the use of the 24 GHz band by Automotive Short Range Radar on an interim basis

An active interest in Car Radar Systems , is that what we will have instead of Functional Internet Access Comreg where you participated actively (or even solely) in defining Functional Internet Access as 0.00 k. You really must show Jesus more respect, you really really must , 10k min. !

Any other useful spectrum lads ????

Co-ordination for use of the frequency of 846 kHz in Ireland is
complete. Due to the nature of radiowave propagation at these
frequencies, this frequency is not usable above 300 watts in Ireland
in order to avoid harmful interference to the service area of a cochannel
transmitter located in Rome.

FFS , did yiz leave out a zero or two in there ???? nuthin else is there?

ComReg, as part of its approach to dealing with congestion and encouraging efficient use of fixed service spectrum, is considering a liberalised approach to new frequency bands to allow the market to decide on the optimum use, e.g. for fixed links or fixed wireless access. In this regard, views were requested on the future use of the 4 GHz (3800 – 4200 GHz) band

<Pricks Ears>

It is apparent from the responses received that there is no consensus on the future use of the 4 GHz band. ComReg has decided to wait for the nature of demand to become clearer

and a punt on 58 GHz in case we care

There were four responses relating to the second proposal concerning bands such as 58 GHz. Two of these held no current views and another felt that such bands were currently of no interest.

Nothing in other words. 35 pages of it .

Even Buttsy could not enthuse a decent press release out of it.

The Chairperson of ComReg, Isolde Goggin said: “I very pleased (SIC) with the high level of interest in this consultation which reflects the importance of wireless communication to Irish consumers and businesses. Many respondents put forward a number of helpful suggestions on how ComReg might develop its Spectrum Management Strategy. ComReg intends to publish the Spectrum Management Strategy in the coming months having taken into account all the input received and analysed in the document.”

Jesus loves you too Buttsy but try " I AM very pleased " next time willya

Thrumm , Thrumm , Thrumm , PUB

vector

>ComReg is proposing to permit Wireless Public Address Systems in the band 27.6 – 27.99 MHz to meet the needs of religious and other community organisations.

Some churches, aparently, broadcast their services around 27Mhz (that is CB) so elderly people etc can listen at home.

Sponge Bob

No usable spectrum for Wireless BB is the problem Vector. Comreg had a go at peddling the 26Ghz band and the 58Ghz band but nobody was interested in them because kit is hard to get and expensive .

The 3G operators frightened Comreg out of any useful initiative below 5Ghz . Comreg (OTOH) evidently has no strategy for the band between 5Ghz and 6Ghz where there is a lot of highly usable spectrum available or for anything higher either I fear

All in all a document which is spectacularly lacking in vision and strategy , just like its authors . We should call it the "Jesus saves but Comreg sits on the Ball and Bursts it " skool of regulation .

( And Congrats to Buttsy for finally cleaning up his press release as suggested I Am Very Pleased with you too . )

BrianD

If you look at the submissions by the private individuals on that list you'll probably find that they are also supporting the licensing of religious radio services. Interesting that the God bothers were unable to get their AM service up in running in the Dublin area but are able to operate a powerful AM service up in Monaghan (549AM) and I believe that 846AM is also used by another religious broadcaster. Many churchs use the FM band 106-107 for broadcasting mass - take a trip down the country and you'll hear many of them on in the morning and of course, Sunday. Can be funny as sometimes they forget to switch off the mics and you can hear the cleaners chatting away. I'm hoping they'll mic up the confession boxes soon and we'll hear some juicy gossip.

jesus_thats_gre

Sponge Bob wrote:

All in all a document which is spectacularly lacking in vision and strategy , just like its authors . We should call it the "Jesus saves but Comreg sits on the Ball and Bursts it " skool of regulation .

Sponge Bob wrote:

An active interest in Car Radar Systems , is that what we will have instead of Functional Internet Access Comreg where you participated actively (or even solely) in defining Functional Internet Access as 0.00 k. You really must show Jesus more respect, you really really must , 10k min. !

Let me get this straight..

Comreg are looking at other areas besides internet access such as Car Radar Systems and other services. You are criticising them for not addressing the issue of Function Internet Access.

They have obviously failed in the area of Functional Internet Access but how is looking at other areas that need attention "spectacularly lacking in vision and strategy".

jesus_thats_gre

Sponge Bob wrote:

The 3G operators frightened Comreg out of any useful initiative below 5Ghz

Have they not spent a couple a hundred million on this licensed band?

Sponge Bob

jesus_thats_gre wrote:

Have they not spent a couple a hundred million on this licensed band?

Does this entitle them to all of it somehow?

The 3G operators have already (in effect) gotten the spectrum between 2,5Ghz and and 2.6Ghz before they even launched. What have they done with it can you tell us. ?

Now they tell Comreg they want 3.6Ghz -4.2Ghz for backhaul, can you explain why and also explain why it cannot be used for Wimax FWA instead ?

BrianD

Here's the solution - set up the following organisations:

Irish Christian Community Broadband
Functional Family Broadband
Saintly Wireless Internet

And you'll have all the licences, access and spectrum you need!!

jesus_thats_gre

Sponge Bob wrote:

Does this entitle them to all of it somehow?

The 3G operators have already (in effect) gotten the spectrum between 2,5Ghz and and 2.6Ghz before they even launched. What have they done with it can you tell us. ?

It entitle them to all of it if the rest of the world is using the same standard. Do you propose that Comreg re-allocate some of this and in doing so causing us to have a different implentation than the rest of Europe.

Regarding the spectrum being reserved before launch. Would you advise releasing an alternative service that uses this spectrum prior to 3G being rolled out and then incurring the cost of replacing out or re-configuring the equipment required to use said service once 3G had been launched?

I appreciate it is unlikely that UMTS coverage will ever reach the same level of coverage that GSM has but what are the actual commitments made as part of the 3G licenses?

The few areas that will not be covered by 3G will be areas of very low population density only, where very few possible services exist that could actually make use of the reserved spectrum while also beomg offered as a viable product.

Sponge Bob wrote:

Does this entitle them to all of it somehow?
Now they tell Comreg they want 3.6Ghz -4.2Ghz for backhaul, can you explain why and also explain why it cannot be used for Wimax FWA instead ?

I presume it cannot be used for WiMax because 3G operators need to use it for backhaul Is there any WiMax operator that is gonna shell out near 300 million in license fees for that band?

I know networks in Ireland, such as the one offered by Vodafone, is far more dependent of radio links for backhaul than nearly every other network in Europe. I am sure that during the negotiations for the 3G licenses, the operators stated that they needed access to this band for backhaul.

bminish

jesus_thats_gre wrote:

I know networks in Ireland, such as the one offered by Vodafone, is far more dependent of radio links for backhaul than nearly every other network in Europe.

something to do with the cost of access to the fixed network of the incumbent telco perhaps? Nothing to do with Comregs fine upstanding work to date of course ..

I am sure that during the negotiations for the 3G licenses, the operators stated that they needed access to this band for backhaul.

Why can they not do backhaul on 6 ,7 18 or 36 Ghz point to point bands like everyone else?
Sub 5 Ghz spectrum is very valuable real estate, the lower you go the better you get at going though walls, trees etc; none of these features are relevant for backhaul links which are always Point to point links with good clear LOS.

For Wireless point to Multipont Comreg have tried to 'interest' providers with bits of difficult to use spectrum that in general do not even match up with allocations in other EU countries. Like the 10.3 Ghz slice that they took off the amateurs that doesn't frequency co-ordinate with the same slice of spectrum in the UK or the North of Ireland, despite careful explanation of this matter in response to the consultation.

Or perhaps the 26 Ghz slot that they have been offering of late to MMDS operators to do broadband with (who already have good working solutions at 2.5 Ghz for use in other jurisdictions ) Not many takers for that considering the extra base station requirements, the esoteric (I.e expensive client kit) and the need for an extra antenna on each customer's premises

Comreg's spectrum 'planners' are also the gob****es who invented the 15 Km Exclusion zone outside the 15Km radial service areas for the 3.5 ghz licence. Exclusion zones are not required anywhere else or in any other wireless service , a frequency co-ordination policy is all that is required.
Where else in the world does one have a regulator that introduces a licencing scheme that potentially denies coverage to 3 times the area that it is licencing for.

.Brendan

jesus_thats_gre

I am speechless... What you say makes sense..

I wasn't defending Comreg as such, just didn't like the general bashing for the sake of it that Sponge Bob seemed to be doing..

I retract all..

Capt'n Midnight

bminish wrote:

Comreg's spectrum 'planners' are also the gob****es who invented the 15 Km Exclusion zone outside the 15Km radial service areas for the 3.5 ghz licence. Exclusion zones are not required anywhere else or in any other wireless service , a frequency co-ordination policy is all that is required.

Isn't this just a means of encouraging value so companies can concentrate on thier geographical area and not having to waste resources on competition.

bminish

Capt'n Midnight wrote:

Isn't this just a means of encouraging value so companies can concentrate on thier geographical area and not having to waste resources on competition.

Well this may be be the case but it's a silly way to do this. Take Galway as an example

Galway has four 3.5 ghz operators all centred more or less on the City.

However East Galway County is outside the coverage area but within the exclusion zones. There are also operators in the midlands with exclusion zones that would prevent the Galway operators expanding out to cover east Galway and of course the Galway exclusion zones prevent the midlands based operators covering this area either. Top marks go to Comreg again

In Rural areas one needs the biggest catchment area possible to be viable, some of the pre wimax vendors (& operators do not have to use pre-wimax kit on 3.5 Ghz if they don't want to ) will go to 30Km + with good LOS why impose an artificial regulatory limit at 15km, what does it achieve?

Surely it makes better sense to just issue 30 Km licences to the operators and drop all this exclusion zone rubbish.

.Brendan

damien

Brendan, are you going to send in your views on this to them as part of a submission in reponse to their strategic consultation doc on telecoms? Sounds like something they need to be informed about. Everything you send in goes into public record too so they can't say they weren't informed.

bminish

damien.m wrote:

Brendan, are you going to send in your views on this to them as part of a submission in reponse to their strategic consultation doc on telecoms?

I don't see much point since they are unlikely to revisit the 3.5 ghz licences issue now that they have started handing out licences.

Sounds like something they need to be informed about. Everything you send in goes into public record too so they can't say they weren't informed.

I have had dealings with Comreg and it's predecessor the ODTR for years, Informing them of things does not appear to make any difference to policy.

.Brendan

eircomtribunal

Damien,
I have great respect for your optimism (and I have bouts of it myself sometimes) with regards to ComReg having any intention to listen to, look at or meaningfully consider our opinion.
If we were in their position – being accountable to nobody – we might possibly become just as .....

I had my own suggestions about the 3.5 gig licences put into questions to Comreg, which were answered as follows:

Question 1: Will a service provider covering a rural area with a potential
uptake of say less than hundred customers have to pay the same annual
3.5 gig licence fee (2800 euros?) to Comreg as the providers in the
urban areas? If so, what is ComReg suggesting to do about the clear
disadvantage of providers who risk to take on thinly populated areas?

Answer:
Yes. The rules of the licensing scheme are clear, providers can make up
their own minds as to whether they wish to operate under this scheme.

Question 2: What is nearest distance another 3.5 gig service provider can get a licence from, say Galway, where all four 3.5 gig segments have been
taken up? Or in other words: Can somebody provide a 3.5 gig service in
Tuam, which is closer than 30 miles to Galway?
Can the 30 mile circles, where a certain technical interference related
signal strength is permissible, overlap? I assume they can, as
otherwise "white" areas would be created around areas where all four
segments of the 3.5 gig licence have been taken up. But I would like
confirmation in this.

Answer:

This will depend on the likely potential for interference between 2
neighbouring systems and on coordination agreements between neighbouring operators. The worst case scenario is a separation distance of 60 km between licensed base stations operating on the same frequency channel.

bminish

eircomtribunal wrote:

Answer:
This will depend on the likely potential for interference between 2
neighbouring systems and on coordination agreements between neighbouring operators. The worst case scenario is a separation distance of 60 km between licensed base stations operating on the same frequency channel.[/i]

Gahhh Comreg at their finest again. It is the job of the Regulator to oversee the frequency coordination, not to sit back and wait for operators to cosy up and come back to Comreg with a solution that they both agree on.

Spectrum reuse right up to the boundaries of the coverage areas is both practical and achievable with some careful RF planning, but an effective regulator is required to intervene with sound engineering based solutions if operators don't behave themselves. The Exclusion zone policy is a load of crap from an incompetent regulator.

Just imagine if GSM sites were co-ordinated by Comreg in the same fashion.


.Brendan

Sponge Bob

Nor could I see any mention in that Comreg consultation of the 28 GHz band for UWB use which may possibly go licence exempt in NI ....but again no coordination from Comreg , or vision.

See

http://www.mwee.com/mwee_news/showArticle.jhtml?articleID=57701427

its a different reality over there is it not :eek: ?

The UK consultation also mentioned 11 other (some quite small) bands, none of which are in the Comreg document for use and including 2.5 GHz ....which is possibly not for 3G use even over in the UK which has 4 live 3g operators maybe 4G instead.

Car Radar is all very well I am sure but quick phone calls to the UK are cheap nowadays innit lads ???

"Just imagine if GSM sites were co-ordinated by Comreg in the same fashion. "

we would roam off Spanish trawlers where I live and be thankful for it !!!!!