CEPT SRDs Consultation - JRC Response

We recognise these are complex issues normally outside the main focus of JRC, but in this instance utilities do make current use of the band 870-876 MHz in the UK, and we are exploring opportunities for future deployments to complement systems operating in licensed spectrum.
Thus, JRC is concerned about the changes being proposed to ERC Recommendation 70-03 where they might affect existing and future systems conforming to the Wi-SUN principle.
We do not object to the intention to extend the GSM-R spectrum to accommodate future deployment of LTE-R systems, but we would wish to see legacy systems operating in the band 870-874 MHz continue to be able to be used; and also use the band for future applications to extend utility control into areas which might otherwise be difficult or disproportionately expensive to monitor and control. Ultimately, the cost of deployment of utility control systems has to be borne by electricity and gas consumers, and utilities wish to avoid unnecessary costs which would be to the detriment of energy consumers.