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UK Spectrum Policy Forum Chair, David Meyer, encourages removal of the text on ‘downlink only’ use of the lower UHF band

UK Spectrum Policy Forum Chair, David Meyer, wrote to Digital Economy Minister Ed Vaizey, setting out Spectrum Policy Forum views on recent European Commission proposals around future use of UHF spectrum.

Dear Minister,

Future use of UHF spectrum: European Commission Proposals Members of the UK Spectrum Policy Forum (SPF) support the current discussions initiated by the European Commission towards bringing clarity and certainty about access to the UHF spectrum in the medium term. This will enable decisions on future investment to be taken. However, we urge you to seek the removal of the text on ‘downlink only’ use of the lower band.

The SPF held a workshop in London last week on the topic of future use of UHF spectrum. The purpose was to prompt wider discussion on the UK market context for the Commission’s draft UHF proposal, particularly in relation to future use of the sub 694MHz spectrum. During the workshop we also touched on key issues on UHF spectrum needs in the UK more broadly, including key points for further discussion within the SPF.

In relation to the Commission’s draft text on ‘downlink only’ use, the broadcast industry view was that the proposal for flexible use below 694MHz was intended to protect broadcasting industry interests, but recent market developments (e.g. suggestions for LTE ‘supplemental downlink’ technology) seem to be putting this into question. Although TV viewing is increasingly taking place over hybrid platforms, or via mobile devices, the current DTT platform has been optimised for PSB service delivery, providing the required coverage, reliability and availability as well as providing a value proposition that allows for funding to be directed at generating valuable UK content. It is not clear that a further reduction in spectrum can be accommodated by the current platform without significant changes to its design being required.

The mobile industry view was that more spectrum below 1GHz is going to be required for future mobile systems (including 5G, which will have coverage objectives in the same way as 4G does), but that downlink-only planning below 694MHz is not optimal. Given that 800MHz spectrum will continue to be required for 4G for some time, and that 700MHz – once cleared for mobile use – might also be used for 4G, 5G could suffer from not having a viable spectrum band for coverage without further (paired) sub-1GHz spectrum. A further view from one MNO was that the potential for sub-700MHz downlink-only LTE technology is highly uncertain, due to small market size, and complex implementation in devices and networks.

Hence both the broadcasting and the mobile industries are of the view that the flexible, downlink-only systems proposal could result in sub-optimal use of UHF spectrum in Europe, but for different reasons. They would prefer any text to be technology-neutral.

In regard to timing, there are strongly held views from the UK broadcast industry in favour of protecting DTT’s status and use of the sub-694MHz for the next decade (i.e. policy review not before 2025, as originally proposed). There are equally strongly held views from the UK mobile industry that the 2025 date is problematic, since international discussions on the future use of UHF spectrum are expected to take place considerably before this (in the context of the provisional agenda item for WRC-23, and the preparations required for this, potentially requiring a European view on the scope of the WRC-23 agenda item to be in place by 2019).

Overall however, both industries would also welcome a clear roadmap for future decisions on UHF spectrum, both in the UK, and Europe. The PMSE sector was also represented at the SPF workshop. As you are well aware, they are increasingly concerned by moves which will restrict the availability to them of UHF frequencies for which so much of their equipment is designed, including equipment purchased as a result of the 800MHz clearance scheme. We would encourage you to seek broad European (and, if possible, global) support for alternative frequencies outside the 470-900MHz band for PMSE so that affordable equipment can be developed quickly.

Yours sincerely,

David Meyer
Chair, UK Spectrum Policy Forum

For further information regarding this workshop of the UK Spectrum Policy Forum please contact Skye MacLeod, Programme Manager

T 020 7331 2191 
E skye.macleod@techuk.org