JRC Publications

This is a list of the latest JRC Public Documents.

JRC response to Ofcom Strategic Review of Digital Communications. Discussion document

The aim of the review is to make sure digital communications markets continue to work for consumers, citizens and businesses. It considers future policy challenges across fixed, mobile and content sectors. This Ofcom document is consulting stakeholders to hear from everyone involved in digital communications services, including consumers, businesses, communications providers and public bodies, from across the UK’s nations and regions. We are also interested in the views of policy makers and legislators who set the statutory framework that we operate in.
JRC notes that Ofcom’s ‘key goal of our strategy is to make sure that the UK’s citizens and businesses are served by high-quality, widely available telecoms, both fixed and mobile. JRC highlights that the stable supply of electricity is an essential resource for the delivery of almost all goods and / or services to UK citizens and consumers, e.g. high-quality, widely available telecoms, both fixed and mobile.

JRC response to the Ofcom framework for spectrum sharing

Demand for spectrum is growing significantly and will continue to do so. Spectrum sharing will become increasingly important to serve that demand. This Ofcom document proposes a new framework for our thinking about spectrum sharing, which will offer a model for systematically considering whether frequencies have the potential to be shared. Ofcom expects to use this framework when defining new spectrum authorisation and when seeking to identify spectrum to meet new demands.
JRC notes Ofcom's objective to ensure the appropriate spectrum is available to meet demand from both new and existing uses and minimise the scope for spectrum to remain underutilised. It is therefore hoped that Ofcom will recognise the importance of the UK-wide supply of electricity and facilitate the availability of spectrum for new and existing Utility Operations systems. JRC notes that Ofcom could 'include information on actual use (rather than authorisations)' and is therefore very concerned that Ofcom may publish information that could jeopardise the safety and security of the UK's critical national infrastructure (CNI), and seeks assurance from Ofcom that this will not be published.

JRC Response to the Call for Input on the Ofcom Strategic review of satellite and space science use of spectrum

This Call for Input asks for stakeholders’ input to Ofcom’s strategic review of spectrum used by the satellite and space science sectors. The review aims to look forward over the medium and long term, up to around 20 years out. This timeframe reflects the long planning times and lifecycles for satellite and space science investments, and the long lead-time for any potential regulatory changes that require international agreement.
JRC highlights that the importance of a satellite system is not necessarily proportional to the amount of data that it communicates. For example, the whole of the UK’s gas and transmission network requires less than a kilobit per second of data back-hauled primarily by satellite to monitor and control the entire high and medium pressure network. JRC highlights that satellite communications are playing an increasingly important role in utility operations to complement terrestrial communications in remote areas where terrestrial communications are disproportionately expensive and to enhance telecommunications resilience for the benefit of all UK citizens and specifically electricity and gas consumers. JRC notes that Ofcom is 'seeking to make more and better information available to stakeholders on spectrum use.' JRC is concerned that Ofcom does not publish information that could jeopardise the security of the UK's critical national infrastructure (CNI), and seeks assurance from Ofcom that this data will be protected.

JRC response to Ofcom Business Connectivity Market Review. Review of competition in the provision of leased lines

Ofcom’s Business Connectivity Market Review examines the markets for the provision of leased lines to businesses in the UK. Leased lines are high-quality, dedicated, point-to-point data transmission services used by businesses and providers of communications services. As well as being essential components of many businesses communications systems, they are also essential to support the provision of mobile telephone and fixed residential broadband services. Every three years, Ofcom conducts a review of competition in the markets for the provision of leased lines in the UK.
JRC advises that some licensed utility operators responsible for managing critical national infrastructure are limited to only migrating to the Ethernet systems if they continue to require services supplied by BT. There is some concern regarding the power resilience of these services from end to end. JRC advises that electricity and gas distribution and transmission operators responsible for managing critical national infrastructure have plans to migrate in a timely manner to self-managed resilient radio-based or other systems. It is important that these CNI sectors are not exposed by early termination of VLB services, or as regulated industries themselves, are not subject to significant price increases for this service.

JRC Response to the Ofcom consultation on the Business Connectivity Market Review. Very low bandwidth leased lines.

This document concerns Ofcom’s proposal for retail very low bandwidth (VLB) leased lines in the UK. These services provide dedicated, symmetric, data connections with either analogue or digital interfaces operating at bandwidths lower than 2Mbit/s. Ofcom seeks stakeholders’ comments on its proposals that with effect from 1 April 2016 it should remove all current regulations from BT’s retail provision of VLB leased lines and also modify similar regulations which currently apply to KCOM. Several operators of public services, such as water and energy utilities, still use some legacy data services which provide dedicated analogue and very low bandwidth (lower than 2Mbit/s) connections for critical applications, i.e. monitoring, protection and control of electricity and gas networks, and are still likely to be using them during the next BCMR period.
JRC advises that some licensed utility operators responsible for managing critical national infrastructure are limited to only migrating to the Ethernet systems supplied by BT. There is some concern regarding their use for resilient machine to machine (RM2M) systems.

JRC response to Ofcom Review of spectrum fees (Fixed links and Satellite Services)

This is an initial consultation on a review of spectrum fees for all authorisations for fixed links and satellite services. The starting point for the fees proposals is a report commissioned from Plum Consulting that addresses a range of issues including estimates of opportunity cost for fees based on Administered Incentive Pricing (AIP). This consultation does not propose new fees levels, but seeks stakeholders’ views on the opinions expressed by Plum in its report, etc.
JRC notes that the proposed 1.4 GHz band fees may be 4 x the current fees.
JRC is concerned that Plum’s analysis concentrates solely on economic values, discounting socio-economic value. Table 3-1 illustrates that the lower frequency bands are of greater importance from a socio-economic viewpoint than higher frequencies due to the predominance of public safety and utilities at the lower frequency end of the scale.

JRC response to the Wireless Telegraphy (Licence Charges) (Amendment) Regulations 2015 proposal

The document consulted on proposals to change the current licence fees for some Wireless Telegraphy Act products. This was part of the fourth phase of an increase in fees for aeronautical licences, announced in June 2011. The proposed regulations will also introduce fees for high duty cycle network relay points, which connect individual devices together and to connect them to networks. Furthermore, the proposals set out to make some minor modifications to the definitions used in relation to fixed link and business radio licence fees.
JRC is pleased that High Duty Cycle Network Relay Points licences have been made available because this spectrum may be suitable for applications including Smart Meters.
JRC is also pleased that additional 400 MHz UHF spectrum is being made available to Business Radio users because this spectrum may be suitable for resilient machine to machine (RM2M) Utility Operations systems, e.g. Smart Grids.
JRC identified a potential knock-on issue if UHF Band I and UHF Band II become referred to as the UHF Band within the licensing process. See the response for more details.

JRC Response to Ofcom Strategic Review of UHF spectrum 420-470 MHz.

In December 2014 Ofcom launched a strategic review of spectrum in the band 420-470 MHz. This band is of great importance to JRC members as they operate a large range of services in these bands, and have many emerging needs which cannot yet be fulfilled as there is no further spectrum available. JRC's response is that interference into the band from mainland Europe is not sufficently serious to justify wholesale realignment of the band. JRC members require access to more spectrum immediately to make their utility networks more intelligent. This may be possible if goverment users allow their spare capacity to be shared with commercial users.

JRC Response to the Notice of proposals to make The Wireless Telegraphy (Control of Interference from Apparatus) Regulations 2015

Ofcom proposes to make regulations under section 54(1) of the Wireless Telegraphy Act 2006 prescribing a requirement that is imposed on the use of apparatus after it has already been placed on the market or put into service and has reached the end-user.
This JRC Response highlights, inter alia, that the Proposed Regulations may not meet Ofcom's intentions.

JRC Response to the Ofcom consultation on the Variation of the Spectrum Access Licence for 1452-1492 MHz

JRC does not agree with the technical analysis prepared by Qualcomm. Also, if a guard band is needed to protect services in the adjacent bands from interference caused by the change of use of the ‘Qualcomm’ band’, then the guard band must be contained with the band where the new service resides, not carved out of adjacent bands. ...