Ofcom Statement and Consultation - Expanding spectrum access for fixed links in the 32 GHz band - JRC Response

JRC is pleased to note Ofcom’s proposal to enable Ofcom licensed fixed link access to the 32GHz frequency range. With the withdrawal of other fixed link bands, e.g. 1.4GHz and 26GHz, it is imperative that alternative options are enabled to address the increasing need for backhaul spectrum anticipated by the Energy Networks Operators as they seek to implement a private LTE (pLTE) based enhanced Operational Telecommunications capability (subject to spectrum access).

Ofcom Call for Inputs - Improving Mobile Connectivity from the sky and space - JRC Response

Energy Network Operators make significant use of narrow band terrestrial systems within VHF Band 148.0 to 149.0 MHz for a range of mission critical operational telecommunications services, to ensure the operational integrity of critical national infrastructure.
Sharing studies in 2002 demonstrated that the proposed MSS satellite services were unable to reliably detect and avoid the incumbent terrestrial services within the VHF band and the then Minister of State for E-Commerce and Competitiveness rejected any proposed use of the 148.0 - 149.0 MHz band for MSS satellite services at that time.

Ofcom Consultation – Enabling mmWave Spectrum for new uses - JRC Response

In light of Ofcom’s approach to clear fixed links from the High-Density Areas (HDA) whilst allowing them to remain in the non-High-Density Areas and the intention to establish a technical co-existence regime to afford appropriate protection of fixed links in non-HDAs then we encourage Ofcom to revisit its decision to block changes to existing links and the deployment of new fixed links in non-HDAs. 

Ofcom Statement & Consultation: Increasing use of the 27.5 – 30.0 GHz band - JRC Response

JRC is pleased to note Ofcom’s proposal to enable Ofcom licensed fixed link access to the frequency range. With the withdrawal of other fixed link bands, e.g. 1.4 GHz and 26 GHz, it is imperative that alternative options are enabled to address the increasing need for backhaul spectrum anticipated by the Energy Networks Operators as they seek to implement a pLTE based enhanced Operational Telecommunications capability.

Ofcom CFI - Expanding Spectrum Access for Satellite Gateways (Q / V and E bands) - JRC Response

JRC encourages Ofcom to protect the performance characteristics of existing and future fixed links in the 38 GHz band and to ensure thorough independent interoperability tests have been undertaken before the new services are introduced.

Ofcom Review of the use of Fixed Wireless Links and Spectrum Implications - JRC Response

The Energy Network Operators primarily utilise fixed links as backhaul from hilltop and rooftop locations to transport SCADA and mission critical voice services from a range of distributed energy infrastructure back to regional control centres in order to facilitate the real time monitoring and control of the UK’s energy infrastructure (i.e. mission critical operational Telecoms of Critical National Infrastructure). There are also instances of fixed links being used to connect directly to some large primary substation for the purposed of diversity and / or teleprotection services (an extremely low latency application without which electricity networks cannot operate safely). 

Hybrid sharing: enabling both licensed mobile and Wi-Fi users to access the upper 6 GHz band - JRC Response

The fixed links used by the utility sector in the upper 6GHz band support mission critical communication links supporting the real time control and monitoring of electricity system assets. Any impact on quality or availability of these links will impact the stability of the electricity distribution grid and in certain circumstances could result in power outages. To this end, we are seriously concerned that insufficient importance is being attached to the stable operation of mission critical fixed links when compared to the perceived socioeconomic benefits of incremental enhancements to consumer grade Wifi or LTE connectivity. 

Ofcom Call for Input: Potential spectrum bands to support utilities sector transformation.

Noting the spectrum options under consideration we welcome the emphasis placed on sub 1 GHz spectrum options aligned to 3GPP designated bands. The approach adopted to assess the suitability of the bands is very constructive and addresses the core considerations. We recognise that with any bands there will be constraints and complexities to be worked through and Ofcom have successfully identified the aspects to be addressed. In terms of the sub 1-GHz frequency options the ENA-STG Members and JRC have undertaken extensive studies / analysis to establish the performance / capability of the LTE technology relative to the existing and known future use cases from an enhanced operational control perspective and have responded in detail on the individual bands. To this end we note that the sub 1-GHz bands are well aligned to the needs of the Energy Network Operators and therefore encourage Ofcom to further explore the potential for these bands to be made available to enable the ‘Net Zero’ transition. 

Ofcom: Hybrid sharing enabling both licensed mobile and Wi-Fi users to access the upper 6 GHz band - JRC Response

JRC is not concerned with the differences between WiFi and LTE in outdoor Vs indoor implementations. From a JRC perspective, both technologies and all deployment scenarios represent a real and increased interference threat to mission critical fixed links; as demonstrated in Ofcom’s desktop analysis and through field measurements carried out by UTC in North America. 

Ofcom Consultation - Unpaired 2100 MHz Consultation - JRC response

JRC is pleased that this block of unused spectrum is being considered for alternative uses: 
• It is positive that one of Ofcom’s considerations is that a possible alternative use could be to enable the deployment of utility smart grids. However, spectrum at this frequency would be seen as complementary to priority spectrum (sub 1GHz) which is essential to establish cost-effective and robust wide-area operational communications coverage; and 
• There is not a clearly available ecosystem of hardware vendors for the frequency range under consideration. This would inhibit (possibly completely) any deployments.

Ofcom’s proposed plan of work 2023/24 - JRC Response

We note that almost every work item included in the 2023-2024 programme is dependent upon a secure, reliable and resilient energy supply. Specifically, section 2.2 makes mention of ‘Secure and resilient Telecoms Infrastructure’. We observe that in a world where almost every aspect of daily life is dependent upon an online service and internet connection of one form or another that the need to ensure a constant and stable energy supply is more important than ever – especially during the transition to an economy that is net zero and dependent on distributed renewable energy (DER) sources. Disruption to energy supplies has always had the potential for massive disruption to society but in the third decade of the 21st century it is difficult to overestimate the potential impact to society of any loss of energy supply, even when compared to the situation at the beginning of this century. Resilience and reliability of the UK’s intrinsically coupled energy and telecommunications infrastructure has never been more important.

Spectrum for the Police Service of Northern Ireland - JRC Response

The Joint Radio Company (JRC) welcomes the opportunity to provide input to the Ofcom Consultation: Spectrum for the Police Service of Northern Ireland and the emphasis that Ofcom is placing on enabling dedicated spectrum access to the PPDR community of Northern Ireland. However, we encourage Ofcom to broaden their perspective on Critical System Operators beyond just the PPDR community to ensure that all needs are addressed. In particular, we encourage Ofcom to include the needs of the Energy Network Operators in this discussion and in so doing align this initiative with the existing Strategic Review of the Utility Operators’ spectrum requirements underway with Ofcom.

BEIS: Net Zero Review - Call for Evidence - JRC Response

Our response centres upon the important role that dedicated radio spectrum access will play in efficiently achieving ‘Net Zero’, while avoiding market and regulatory failure through appropriate policy interventions.
A bespoke radio-based communication network is the most cost-effective option to provide UK energy network distribution and transmission operators with the necessary, resilient real-time command and control capability to manage an increasingly complex and integrated, low carbon energy system. As we transition to Net Zero, energy networks will need to be more flexible to connect more renewable generation, energy storage systems, and millions of low carbon devices – such as electric vehicle chargers, heat pumps and micro-generation – across every tier of the UK energy system.

Project Co-ordinator Job Description

Ofcom Enabling mmWave Spectrum for new uses consultation - JRC Response

·        In light of Ofcom’s approach to clear fixed links from the High-Density Areas (HDA) whilst allowing them to remain in the non-High-Density Areas and the intention to establish a technical co-existence regime to afford appropriate protection of fixed links in non-HDAs then we encourage Ofcom to revisit its decision to block changes to existing links and the deployment of new fixed links in non-HDAs;

·        The Costing Model does not fully reflect the actual costs for the systems deployed by JRC’s Members and we encourage Ofcom to revisit the underlying cost components and the scenario that should be applied;

·        With regard to the establishment of a co-existence regime with fixed links JRC and its Members are keen to work with Ofcom to ensure that the technical coexistence arrangements established afford appropriate protection particularly in light of the suggestion to revisit the decision to block modifications to and new fixed links in the band.

Ofcom Future Approach to Mobile Markets / Meeting future demand for mobile data - JRC Response

Ofcom has focused the provision of spectrum access to Mobile Operators over the last 20 years, but it is important that Ofcom does not lose sight of the spectrum access needs of other platforms / systems, e.g. Energy Network Operators, Broadcasting, Transport, PMSE, etc. To this end we are very supportive of the work underway in Ofcom’s ‘Spectrum for Utilities’ study and our response centres on the importance of ensuring that appropriate spectrum access is afforded to other users in order to support Government policy, i.e. the ‘Net Zero’ transition. 

Ofcom Enabling Spectrum Sharing in the Upper 6GHz Band - JRC Response

Ofcom has focused the provision of spectrum access to Mobile Operators and WiFi providers over the last 20 years. It is important that Ofcom does not lose sight of the spectrum access needs of other platforms / systems, e.g. Energy Network Operators, Broadcasting, Transport, PMSE, etc. To this end we are very supportive of the work underway in Ofcom’s ‘Spectrum for Utilities’ study and our response centres on the importance of ensuring that appropriate spectrum access is afforded to other users in order to support Government policy, i.e. the ‘Net Zero’ transition.

Operational Control of Mission Critical Networks and the Service Limitations of Public Mobile Networks (JRC White Paper)

This paper explores the approach adopted by Mobile Network Operators (MNOs) in providing a service to UK customers and in this context acknowledges the limitations that exist for these services to be used for the Operational Control of Mission Critical Networks, e.g. Energy Networks. Whilst the regulatory framework has encouraged market competition for service provision it has not encouraged the types of investment necessary to facilitate the needs of Critical Network Infrastructure Operators, e.g. the Energy Network Operators. 

The issues of note are included within the document. 

Gemserv Economic Study Press Release

Economic rationale for enabling Smart Grid functionality of the UK energy system via a Private Radio Frequency based enhanced Operational Communications

Ofcom Administered Incentive Pricing for the 412–414 MHz, paired with 422–424 MHz, frequency bands - JRC Response

JRC considers the AIP process as a logical method of setting the annual fee for the 412 / 422 MHz spectrum.

The proposed AIP pricing reflects the Area Defined spectrum access costs for the adjacent UHF1/2 bands channels and the High Band channels. 

JRC Response to RSPG Questionnaire Regarding Climate Change

JRC Response to RSPG Questionnaire Regarding Climate Change

Ofcom Plan 2021-22 JRC Response

Ofcom Plan 2021-22 JRC Response

Ofcom Annual Plan 2021-22 - JRC Response_.pdf

Ofcom Annual Plan 2021-22 - JRC Response

Ofcom ‘Spectrum Management for the 2020s’ Consultation - JRC Response

JRC and its Members welcome the opportunity to respond to this consultation to address the Spectrum Management developments for the 2020s and provide an Energy Network Operators perspective on the proposals. 

JRC recognises the emphasis being placed on Business, Public Sector and Industry users and welcome this approach;
JRC is supportive of increased spectrum access to support innovation and future demands subject to appropriate protection being afforded to incumbent users, in the case of Energy Network Operators existing spectrum access enables critical national services and any disruption is to be avoided;
Spectrum users depend on long term stability of spectrum access to enable the investments made. The current proposals have the potential to undermine this principle as Ofcom proposes to change the technical parameters against which systems have been designed with the resulting displacement, disruption and unanticipated need for expenditure to comply with such change. We encourage Ofcom to undertake a robust Cost Benefit Analysis (CBA) to establish whether the additional spectrum access that might be enabled via a change warrants the additional cost, risk and disruption to incumbent services;
We encourage Ofcom to further develop their internal systems as a ‘computer says no’ response can be an obstacle to innovation. An example would be an inability to accommodate wider channel blocks in the VHF and UHF bands. Ofcom should seek to ensure that their internal systems for licensing and co-ordination continue to reflect changes to industry needs and as such do not stand in the way of spectrum access to address market / industry developments; and
Whilst there is a major focus within these proposals for increased spectrum sharing we encourage Ofcom to firstly appraise the existing approach to spectrum sharing to better understand why uptake has been so low and address any obstacles identified before further sharing is contemplated.

Ofcom’s proposed plan of work 2021/22 –JRC Response

JRC's Response includes the following Ofcom work items: Copper retirement (PSTN withdrawal), Network Security and Resilience, Award Spectrum Bands as they are cleared and released, Localised Licensing, Licensing Platform Evolution, Electromagnetic Fields (EMF) and Health, Engaging with Industry on Wireless and Spectrum, Spectrum Management Strategy, Spectrum Roadmap, 2G / 3G Switch-Off, Future of Numbering Policy Review, Vulnerable Consumers, and Spectrum Sector Reviews. 

JRC Response to the Ofcom Proposed measures to require compliance with International guidelines for limiting exposure to electromagnetic fields (EMF)

JRC, representing the UK energy utility sector, has provided input to Ofcom to ensure that the approach that requires compliance with the relevant international guidelines is as appropriate and efficient as practicable whilst at the same time avoids an unnecessary regulatory burden for JRC Members and the UK wireless sector in general.

In light of Ofcom’s latest proposals JRC makes the observations below which are elaborated further within our submission;
• JRC supports Ofcom’s approach and specifically JRC welcomes the proposed technical exemption criteria proposed which will in many instances remove co-ordination obligations on system operators on shared sites;
• Where the technical exemptions do not apply and operators on shared sites are required to co-ordinate to demonstrate compliance, we encourage Ofcom to provide greater guidance as to how the co-ordination process could be administered by operators;
• JRC agrees that Ofcom’s ‘Guidance on EMF Compliance and Enforcement’ is helpful in simplifying calculations and avoiding unnecessary complexity; and 
• JRC has tested the trial version of Ofcom’s EMF calculator and confirm that it produces consistent results albeit we seek a clarification as to whether it is intentionally set-up to produce a ‘worst case’ output, i.e. includes ground reflection as part of the calculation. We also encourage Ofcom to update the calculator to incorporate the latest ICNIRP 2020 guidance.

JRC Response to DCMS Access to Infrastructure Regulations - call for evidence

JRC’s Members, the Energy Network Operators, advise that the following aspects are worthy of further consideration: 
• Ensuring physical security of Critical National Infrastructure and consequential costs in complying with the requirements of NIS regulations and other statutory instruments, needs to be taken into account for Energy Network infrastructure; 

• Confirmation is requested that where permission has been granted to use Energy Network Infrastructure / Assets that this is subject to the sharer or whoever is carrying out the “operational development” (as defined by the Town and Country Planning Act 1990) complying with planning legislation by using any appropriate general permitted development rights or by applying for planning permission.

• Way leave Arrangements - Energy Networks Infrastructure / Assets located on private land where there is a way leave agreement in place with the landowner this is solely for the infrastructure to facilitate Energy supply. If a CSP wishes to deploy communications systems on this Energy Network infrastructure then it should be the responsibility of the CSP / Communications Infrastructure provider to gain a new way leave specifically for the installation and on-going maintenance of any equipment they wish to install and that a copy of this way leave agreement shall be provided to the Energy Infrastructure owner prior to any communications equipment being installed;.

• Where an Energy Network Operator wishes to remove an asset that is used by a third party communications system operator they will be able to serve notice (3-6 months) without penalty, e.g. an overhead line is replaced by an underground overlay scheme.

• We welcome greater clarity on the definition of access, sharing requirements & revocation rights;

• Investigate the implementation of a compulsory “code of practice” between Energy Network Operators and Telecoms Network Operators; 

• Explore the opportunity for greater involvement of the Energy regulator Ofgem in this area to enhance awareness on both sides of the potential impact of enhanced access rights.

 

JRC Response to the Ofcom 'Proposed measures to require compliance with international guidelines for limiting exposure to electromagnetic fields (EMF)' consultation

This consultation proposes to introduce an administrative / operational burden on industry from a compliance perspective. We see no basis for the proposed regulatory intervention and more significantly that there is no justification based on the evidence provided to warrant the imposition of this additional regulatory burden on licensed operators.

Notwithstanding the lack of demonstrable justification for such a regulatory intervention if Ofcom seeks to adopt such an approach then we encourage Ofcom to acknowledge the operational and physical characteristics of the systems licensed to our Members which render them free from harm in terms of their potential risk to the General Public and hence exclude them from the regulations.

JRC Response to Ofcom 'Improving spectrum access for Wi-Fi spectrum use in the 5 and 6 GHz bands' consultation

JRC notes that the energy utilities operate licensed fixed links within the L6 GHz Band and these will need to be protected as primary licensed users of the spectrum.

We encourage Ofcom to establish adequate provisions to address interference and implement an effective process to deal with any link degradation suffered by the energy sector subject to the "Polluter Pays" principle.

JRC Response to Ofcom’s proposed Plan of Work 2020/21

JRC highlights that the Government’s drive for net-zero emissions includes the roll-out of distributed electricity generation sites, e.g. wind farms and solar farms. Like other parts of the electricity grid, windfarms and solar farms require real-time remote monitoring and control. Apart from day-to-day management, one rea-son is to isolate them quickly if they unbalance the electricity grid. Another is to manage their reconnection to the electricity grid after an outage. With the dramatic expansion in active assets across the energy networks and the increasing importance of real-time data to manage the supply and demand dynamic, which is becoming increasingly complex through the adoption of Electric Vehicles, there is an increasing need for spectrum access for the Energy Utilities to facilitate Government Policy outcomes, e.g. net Zero targets. To this end, we are very supportive of the detailed analysis being undertaken by Ofcom to inform its policy with the expectation that, in due course, sufficient spectrum will be made available to the sector.

Final Report published after completion by JRC for WPD of the ‘Next Generation Wireless Telecoms Analysis’ study into the use of LTE connectivity for Smart Grid 4th February 2020

This study has established the principles for the design, co-ordination and deployment of national LTE data communications networks for all DNOs/DSOs in the UK and Ireland and even beyond. An additional objective was to clarify the radio spectrum requirements for such a deployment . . . . . . .

WPD publish Closedown Report after completion by JRC of ‘Next Generation Wireless Telecoms Analysis’ study into the use of LTE connectivity for Smart Grid

The Network Innovation Allowance (NIA) funded ‘Next Generation Wireless Project’, undertaken jointly by Western Power Distribution (WPD) and Joint Radio Company (JRC) has concluded, having met all of its Objectives and Success Criteria .....

JRC response to Notice of Ofcom’s proposals to amend the spectrum trading and register regulations

JRC notes that Ofcom is proposing to go beyond the recommendations of the RSPG and the position adopted by DCMS in enabling access to the lower 2 GHz of the 26 GHz band under the Shared Access Licence provisions. Whilst the regulatory provisions for the lower 26 GHz band are being limited to low power indoor licences for 5G systems we note that the long term viability of this part of the band for incumbent users is likely to be negatively impacted by this action which is not informed by a demonstrable case for the need for access.

We encourage Ofcom to reflect on the guidance from RSPG and DCMS and remove the lower 2 GHz of the 26 GHz band from the Shared Access Licence provisions.

JRC response to the Public consultation on the Draft RSPG Work Programme for 2020 and beyond.

JRC response to the Public consultation on the Draft RSPG Work Programme for 2020 and beyond.

DCMS Implementing the European Electronic Communications Code (EECC) Consultation - Joint ENA & JRC Response

The Energy Networks Association (ENA) and the Joint Radio Company (JRC) welcome the opportunity to provide this joint response to this consultation by the Department for Digital, Culture, Media and Sport (DCMS) on the European Electronic Communications Code (EECC). In so doing we are representing Critical National Infrastructure operators (our members) and protecting their access to suitable spectrum resources to provide for the regulatory and commercial requirements of the services they offer, something that has been eroded by recent regulatory and policy decisions favouring public mobile services to the detriment of our members. We see the continuing access to 26 GHz and other suitable national spectrum for fixed links and radio wide area networking as being crucial to the establishment of ‘Smart Grid capability to deliver upon Government Policy and ensure that the UK energy system is able to transition in a robust and resilient manner to enable the near zero system of the future.

The recent electricity network event in the UK, the Low Frequency Demand Disconnection (LFDD) on 09 August 2019, has again emphasised the requirement for robust resilient real time inter asset communications where radio-based communications are a primary contributor.

House of Commons Roundtable Event - The smart energy blind spot

LCNI: Low Carbon Networks & Innovation Conference

The smart energy blind spot

Current operational telecoms systems are not fit for a distribution system operator future. Here are the key outcomes of a Network debate, hosted in association with Nokia and Joint Radio Company (JRC).

Let's cut to the chase. If we care about mitigating climate change, we need to release radio spectrum to enable the emergence of a smart, flexible, decentralised power grid. This was the clear-cut message that emerged from a meeting of senior industry experts and regulators in the House of Commons.

https://networks.online/gphsn/comment/1001626/smart-energy-blind-spot

JRC Response to RSPG Opinion on 5G implementation challenges (RSPG 3rd opinion on 5G)

JRC observes that the majority of electricity utilities in the UK utilise self-licenced spectrum. This allows their electricity grid control systems to include the necessary resilience requirements, e.g. up to five days power backup. (JRC notes that for the mobile operators it would be uneconomic to construct a business case to support the cost of upgrading mobile operator infrastructure to include the necessary power resilience for such a limited user base).

Moreover, JRC emphasises that the requirement for system resilience has necessitated access to exclusive spectrum, e.g. self-managed 12.5 / 25 kHz narrow band channels and Ofcom (UK) managed channels for the fixed links backhaul.

JRC does not believe the market would be well served if vertical sectors could only access spectrum by leasing from operators or through licence-exempt spectrum. This would be a major detrimental step for spectrum access.

JRC Response to the Comreg Consultation and Draft Decision on the release of the 400 MHz Sub-band

JRC supports the actions of the Commission for Communications Regulation (ComReg) to progress the release of the of 400 MHz spectrum under consideration for ‘Smart Grid’ developments in Ireland.

The principle focus of this response is the change proposed to the spectrum available to the award process, in particular the reduction of the lot B award from 2 x 2.5 MHz to 2 x 1 MHz with 2 x 1.5 MHz being reserved for potential Broadband - Public Protection and Disaster Relief (BB-PPDR) purposes in the future.

NIC The future of regulation study: JRC Response

The Joint Radio Company (JRC) welcome the opportunity to respond to this call for evidence and we acknowledge the underlying perspective that there is an increasing degree of alignment and interdependency developing across regulated Industry Verticals, particularly across Energy and Telecommunications.

As regards the idea of the establishment of a multi-utility regulator, our perspective is that improved co-ordination across the responsible Government departments aligned to co-ordinated and targeted interventions within the existing regulatory frameworks would be a more efficient and timely approach to adopt.

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.

JRC Response to Ofcom Draft Annual Plan 2019/20

JRC highlights that communication networks are dependent on access to resilient and robust electricity supplies. Also, with the evolving Smart Grid, that the existing intelligent electricity monitoring and control systems are being expanded to the extremes of the electricity network. This expansion in the operational communications needs of the energy utilities will require access to additional spectrum. This developing need is being explored within Ofcom’s current direct engagement with the Energy Utilities which we welcome.

To this end we encourage Ofcom to establish a specific work item to further this Industry need. This may be pursued under the heading of ‘Managing spectrum and planning for future requirements’ within the Annual Plan. It is worth noting the ongoing developments within the Republic of Ireland where the Communications Regulator (ComReg) has acknowledged the need for additional spectrum to be made available to facilitate Smart Grid developments and in so doing is proposing to afford access to 2 x 3 MHz of spectrum in the 400 MHz range for the Irish utilities.

ENA Strategic Telecommunications Group, ‘Need for Increased Spectrum Allocation and Investment in Operational Telecommunications to Support Electricity Networks,’ 2018

ENA Strategic Telecommunications Group, ‘Need for Increased Spectrum Allocation and Investment in Operational Telecommunications to Support Electricity Networks,’ 2018

EUTC Spectrum White Paper

EUTC Spectrum White Paper

JRC Smart Grid Briefing Paper

JRC Smart Grid Briefing Paper

2007 UTC & JRC Utility Satellite Technology Study

JRC-UTC Report “Utility Use of Satellite Technology in Emergency Response

ComReg Further Consultation on the Release of the 410 – 415.5 / 420 – 425.5 MHz Sub-band

JRC supports the actions of the Commission for Communications Regulation (ComReg) for the proposed release of the radio spectrum noted and in particular the recommendation to assign 2 x 3 MHz of the band on a service specific basis to enable ‘Smart Grid’ activities in Ireland.
JRC encourages ComReg to adopt an open approach to the operating mode that can be used and in so doing permit both TDD and FDD to be deployed in the band and in so doing allow the entity that wins the spectrum to deploy it in whichever mode best serves their operational requirements.
The roll-out obligations proposed for the Part A lot require further consideration as they appear to be reflective of a typical mobile network roll-out where coverage drives revenue. The drivers behind the deployment of Smart Grid capability will be to establish enhanced asset utilisation, minimise customer outages, allow distributed generation to be connected quicker and increase availability.

ENA Future Worlds Consultation - JRC Response

JRC welcomes the emphasis on Communications Systems Capability as a ‘Key Enabler’ for the ‘Future Worlds.’ It is worth noting that a key input on which operational telecommunications systems depend is radio spectrum. To this end and as part of the ‘Future Worlds’ analysis we encourage ENA and Government to explore the Operational Telecommunications (OT) needs of the Industry and in so doing seek to understand how to best serve these needs through access to both fixed and wireless networks.
There is likely to be a tension between the Economic, Commercial and Financial case. Perhaps the Financial Case could be considered sub-ordinate to the Economic and Commercial cases, since it is likely that Funding issues will be addressed for those Future Worlds that satisfy both the Economic and Commercial criteria.

Ofcom WRC 2019 Preparations - JRC Response

The JRC requests that the UK 26 GHz position be revised to align with the RSPG opinion (RSPG18-005 FINAL).
M2M and IoT appear to have become generic terms for most types of data transmission systems. The term Resilient Machine to Machine (RM2M) is becoming increasingly used to distinguish when an M2M system includes the necessary enhanced resilience.

JRC is concerned that, without sufficient restrictions, non-GSO systems operating within the 460 to 470 MHz band could cause harmful interference to the UK's electricity and gas grid monitoring and control systems.

JRC proposes the introduction of 'Utility Operations' as an ITU defined service in the same way as Public Safety and Disaster Relief (PPDR) and Programme Making and Special Events (PMSE) are identified as distinct services requiring special recognition.

JRC response to ComReg proposed Strategy for Managing the Radio Spectrum - 2019 to 2021

It is important that ComReg does not overlook the importance of spectrum access for uses other than mobile data access. To this end we are encouraged by the initiative to enable access to the spectrum in the range 410-415.5 & 420-425.5 MHz which has the potential to support ‘Smart Grid’ developments in Ireland and be critical to helping the Irish Government deliver upon key environmental targets agreed with the International Community.

Proposed Multi Band Spectrum Award (ComReg Consultation - Ref 18/60)

JRC supports the actions of the Commission for Communications Regulation (ComReg) for the proposed release of the radio spectrum noted and the establishment of a combined award of the bands identified to ensure that complementary bands are made available at the same time.
JRC supports ComReg’s proposal to exclude the following frequencies from the multi-band award process;

• 700 MHz Duplex Gap & Guard Band
• 1.4 GHz Band, both Centre and Extension Bands; and
• 26 GHz Band.

The potential characteristics of use of these bands are different to those considered relevant to the multi-band award and therefore should be treated separately.

Ofcom Consultation: Proposed Guidance on protecting access to emergency organisations when there is a power cut

The four principles proposed in the consultation appear wise and well founded. However, there appear to be a number of significant assumptions in the consultation without the evidential basis to support the position being adopted. These include:

• The assumption that mobile phone networks will provide service during power cuts.
• The one hour minimum power backup duration seems sensible given the Ofgem data that 67% of power outages are restored within 1 hour.
• The assertion that most calls to the emergency services would occur shortly after the initial power outages has no evidential basis.
• Paragraph 3.10 describes a situation where some 'households have a history of long-duration power outages'. It is incumbent on the electricity network provider to remedy known situations.
• The increasing use of fempto cells to provide domestic mobile coverage, back-hauled on broadband, will not work if a power cut is not addressed.

JRC Response to Ofcom Draft Ofcom Annual Plan 2018/19

As critical systems users, the Joint Radio Company (JRC) welcomes the opportunity to respond to this consultation on behalf of the electricity and gas utility operators. JRC highlights that communication networks are dependent on access to resilient and robust electricity supplies. Also, with the evolving Smart Grid, that the existing intelligent electricity monitoring and control systems are being expanded to the extremes of the electricity network. This expansion in the operational communications needs of the energy utilities will require access to additional spectrum.

This developing need is not recognised within the Ofcom Annual Plan 2018/19 and as such we encourage Ofcom to establish a specific work item to address this need.

JRC appreciates the essential work of the Ofcom Field Teams and Spectrum Licensing Teams to support the day-to-day operational telecoms needs of the energy networks.

JRC response to the DCMS Call for Views: 5G Trials and Testbeds Programme

The Joint Radio Company (JRC) welcomes the opportunity to respond to this call for views and in particular we support the approach from Government to provide funding support to 5G developments to enable future UK competitiveness.

In terms of the three use cases to be explored we endorse the observation that Massive Machine-Type Communications will be directly relevant to the ‘Energy’ sector in the future and see merit in linking this initiative to the Energy Network’s Association Open Networks Project which is seeking to establish sophisticated approaches to electricity Demand Management. In addition, when considering Ultra-Reliable, Low Latency Communications URLLC this also has a direct relevance to the Energy Supply Sector. The energy supply sector currently utilises this capability on a limited scale to control power supplies but in future there will be enhanced need for this capability at all levels of the energy network and as such the amount of active network components needing this type of critical communications capability will likely increase by two orders of magnitude.

Furthermore, a key component of enabling URLLC type systems is access to resilient and robust energy supplies and / or having back-up energy present locally. Hence there is a direct relationship between the energy supply industry and future URLLC type solutions from both the Demand and Supply perspectives and we are keen to work with DCMS to establish this aspect as part of future initiatives.

Finally, it is worth noting the emphasis placed by Government on Mobile when describing the 5G initiative and we encourage Government not to overlook the potential for the 5G technology to be deployed in a Fixed Wireless Access context and that this approach should also be considered within the 5G Pilots.

JRC Response to DCMS Future Telecoms Infrastructure Review: Call for Evidence

The Joint Radio Company (JRC) welcomes the opportunity to respond to this call for views and in particular we support the approach from Government to consider alternative market frameworks when seeking to establish the market for ‘future new digital infrastructure.’ Moreover, future Industrial Developments will be predicated on the establishment of next generation digital communications infrastructure that will enable initiatives such as ‘Smart Grid.’ Noting that ‘Smart Grid’ is central to establishing the UK’s ‘Low Carbon Economy’ then we encourage DCMS to ensure alignment between the Policy framework designed to facilitate the new digital communications infrastructure and broader Policy interventions across Government.

In addition, we see merit in considering the role that Industry Verticals, e.g. Energy, Automotive, Health and Care might have when establishing the market framework for ‘new digital infrastructure.’ Moreover, Industry Verticals may facilitate reach and capacity on a truly national basis that has to date not been economically rationale for existing licensed operators.

Finally, we encourage DCMS and Government more broadly to note that the availability of UK Communication Networks is dependent on access to resilient and robust electricity supplies which are subsequently predicated on secure access to interference free wireless-based control systems. To this end, where spectrum access is a key component of enabling Critical Infrastructure such as Energy Networks then this aspect should be captured in DCMS’s ongoing oversight of Critical Communications Infrastructure.

Response to the Ofcom Fixed Wireless Spectrum Strategy

JRC welcomes Ofcom’s understanding that ‘Energy distribution along with all the necessary communications and network management, monitoring and control functions all require high reliability communications infrastructures. A change to a more distributed model could result in additional requirements for fixed wireless links, which we [Ofcom] will monitor’.

JRC also welcomes Ofcom’s recognition that access to suitable spectrum enables ‘the safe and secure supply of water, electricity and gas in the UK’.
JRC highlights that a wide range of channel widths and data rates will continue to be required when the existing electricity grid monitoring and control systems, with their range of technologies, are expanded to the edges of the electricity Smart Grid network, e.g. with 100 times more locations being monitored.

Future Telecoms Infrastructure Review: Call for Evidence

The Joint Radio Company (JRC) welcomes the opportunity to respond to this call for views and in particular we support the approach from Government to consider alternative market frameworks when seeking to establish the market for ‘future new digital infrastructure.’ Moreover, future Industrial Developments will be predicated on the establishment of next generation digital communications infrastructure that will enable initiatives such as ‘Smart Grid.’

Noting that ‘Smart Grid’ is central to establishing the UK’s ‘Low Carbon Economy’ then we encourage DCMS to ensure alignment between the Policy framework designed to facilitate the new digital communications infrastructure and broader Policy interventions across Government.

JRC Response to Ofcom Call for inputs on 5G spectrum access at 26 GHz

As critical systems users, the Joint Radio Company (JRC) welcomes the opportunity to respond to this consultation on behalf of the electricity and gas utility operators.

JRC supports the actions of Ofcom in seeking to identify potential 5G scenarios and the need to understand any system sharing requirements before making long-term spectrum decisions specific to the 26GHz band.

Moreover, as it is unclear at this stage what form 5G services will take in the 26 GHz frequency range, we urge Ofcom to ensure on-going security of access to incumbent services on which the energy utility operators depend.

Potential 5G applications in the band may include backhaul and mobile services. In the case of backhaul this may be similar to existing fixed links services and may be readily accommodated alongside established fixed links within the band. The deployment of cellular type mobile communications within the band may be limited to localised base station to mobile devices in a ‘hot-spot’ type model and, as such, these systems are likely to be targeted to high footfall areas involving small cells embedded within the urban clutter. This may facilitate the opportunity for co-existence with incumbent uses such as fixed links.

Consultation on draft UK Regulations to implement the Radio Equipment Directive (RE-D) into UK law

Overall, JRC believes that this Directive will make a positive contribution to improving radio equipment standards with the long-term benefits of more efficient use of a scarce and valuable resource - the electromagnetic radio spectrum.
JRC also believes that the introduction of mandatory radio receiver performance standards offers the opportunity of reducing interference into radio equipment in the longer term.

Ofcom_Strategic_Review_of_UHF_Band_1_and_Band_2_410_to_470_MHz_(JRC_Response)

This consultation proposes to use the spectrum in the 410 to 450 MHz (UHF Band 1) and 450 to 470 MHz (UHF Band 2) bands more intensively and efficiently to best address the requirements of current and future users.
JRC indicates that the bandwidth requirements of its UHF systems will increase within the medium or long term future. Primarily, there is a requirement to increase its current data rates from 9.6 kbit/s in 12.5 kHz narrow band channels to 64 kbit/s in 25 kHz narrow band channels and ultimately to even wider bandwidth systems with Mbit/s capabilities.
In line with our European neighbours, it will be very helpful if Ofcom can make available sufficiently more spectrum for the resilient machine to machine (RM2M) systems used to control of the UK’s growing critical infrastructure utilities’ Smart Grid(s), e.g. 2 x 3 MHz within the 380 to 470 MHz Band.
Within some European countries, critical infrastructure utility operations already have access to sufficient 400 MHz Band spectrum (typically within 450 to 470 MHz) to operate their Smart Grid systems.

National Infrastructure Assessment Call For Evidence

The National Infrastructure Commission (NIC) launched a 15 week call for evidence to provide input into the development of its National Infrastructure Assessment, and encourages all interested parties to submit evidence, ideas and solutions.
The Commission will produce an NIA once in every Parliament, setting out the Commission’s assessment of long-term infrastructure needs on a 30-year time horizon with recommendations to the government. In completing the NIA, the Commission will build on the work of individual actors, including government departments, sub-national and regional bodies and regulators. The Commission will consider the demand and supply of infrastructure services, such as journeys or communication, as well as infrastructure assets, such as roads or fibre optic cables.
The Commission will cover economic infrastructure in the NIA but sectors will not be tackled independently from each other. The NIA will be developed by assessing the infrastructure system as a whole using a robust, common methodology to develop needs assessments that take account of strategic cross-sector considerations and resilience implications. In terms of the individual sectors, the Commission will cover: transport, digital communications, energy, water and wastewater (drainage and sewerage), flood risk management, and solid waste.
The JRC Response includes highlighting the importance of the continued stable supply of electricity and the future limited spectrum requirements needed to achieve this.

A Smart Flexible Energy System. A Call for Evidence. JRC Response.

The Department of Business, Energy & Industrial Strategy (BEIS), the Office of Gas and Electricity Markets (Ofgem), and the Office of Communications (Ofcom) have differing interpretations of policies and responsibilities with regards to businesses, citizens, and consumers. Under the Communications Act, Ofcom interprets the obligation to serve the interests of 'consumer / citizens' as according higher priority to direct consumer-facing services - mobile data and broadcasting - than communications directly related to delivering cost effective and reliable essential services for the consumer / citizen.

Ofcom Annual Plan 2016-17

Ofcom's main legal duties are to ensure that:
- the UK has a wide range of electronic communications services:
JRC highlights that the wide range of electronic communications services, indeed almost all products and services, that are offered to the UK’s citizens and consumers relies directly or indirectly on the stable provision of electricity and / or gas (gas is used to generate typically 50%[1] of the UK’s electricity) by the UK’s Critical Infrastructure Utility Operations.
The stable supply of electricity relies increasingly on the systems that control the electricity grid. This includes resilient private wireless systems such as the 9.6 kbit/s in 12.5 kHz true[2] narrow band channels used for the UK-wide supervision and data control systems (SCADA).

JRC Response to DCMS Review of Electronic Communications Regulatory Framework

JRC supports ‘deployment of communication networks that meet the needs of users over the next decade enabling competitiveness and economic growth and delivering social benefits. The effectiveness of networks needs to be judged by the quality of experience enjoyed, or suffered, by the user, be they an individual consumer or [a] business’.

JRC's response to Ofcom's Fixed Wireless Spectrum Strategy

Almost all products and services offered to citizens and consumers rely on the reliable supply of electricity and / or gas. In turn, these critical infrastructure utilities rely on the reliable supply of suitable 400 MHz, 1.4 GHz, and other fixed links spectrum to control their grid systems. The move to Smart Grids will require additional suitable spectrum access. In the UK, 12.5 / 25 kHz narrow band channels will continue to be required in the 400 MHz band. Higher data rate systems may require private broadband radio (PBR) channels, e.g. 1.25 MHz bandwidth. Higher frequency fixed wireless spectrum will continue to be required for backhaul links, etc. Critical infrastructure utilities prefer to avoid spectrum above 14 GHz because it is affected by rain, especially during storms when the electricity networks may be under extreme stress.

JRC response to Ofcom More Radio Spectrum for the Internet of Things

There appears to be demand for Machine-to-Machine (M2M) applications, especially in rural areas and hard to reach locations, that require connectivity over longer distances. This Ofcom document aims to encourage investment and innovation in the Internet of Things (IoT) using 10.1 MHz of spectrum within the 55-68 MHz, 70.5-71.5 MHz and 80.0-81.5 MHz bands by using our existing licence products. At the same time, Ofcom seeks views on whether any changes to its existing licence products are necessary to promote innovative uses in these bands, especially for serving rural and remote locations.
JRC highlights that the utilities have been operating Resilient Machine to Machine (RM2M) systems for over 50 years. JRC highlights that, whilst access to more spectrum in bands below 1GHz is needed by the power utilities if they are to fulfil their regulatory obligations to maintain secure and sustainable supplies of electricity and gas, and to restore supplies in a timely manner when those supplies are interrupted for any reason, the proposed Band I and VHF Low Band spectrum may not be suitable.

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.

Equipment Buyers' Information Sheet

JRC is receiving an increasing number of enquiries regarding radio equipment that has been purchased and is subsequently found to be either un-licensable in the UK and / or does not operate to the specification for which it was bought.
JRC therefore offers the following advice. Before considering purchasing equipment, ensure that it: ...

JRC Response to Ofcom consultation on WRC-15

The 1.4 GHz fixed link UHF band (1350-1375 MHz paired with 1492 -1517 MHz) is a valuable asset used by most UK electricity companies for operational communications. It should be protected against surrender to mobile data services unless an equivalent band can be made available in a similar frequency band. In setting the Agenda for WRC18, identifying suitable spectrum for utilities’ operational communications should be included.

JRC Response to UK Digital Communications Infrastructure Strategy

The government strategy aims to ensure that the UK builds on its strong digital foundations to benefit from world class communication networks to support economic growth and wider social benefits. At the same time, the Digital Taskforce wishes to identify any issues that might affect the development and deployment of digital infrastructure and consider how these can be addressed. JRC points out that without reliable electricity supplies, the most advanced digital communications network in the world is worthless.

Promoting Innovation and Investment in the IoT

JRC's response to Ofcom's document "Promoting Innovation and Investment in the IoT" highlights that utilities have for over half a century used machine-to-machine communications, but the security, resilience and latency requirements are far more stringent than the newly recognised M2M category. The growth of intelligent utility networks will result in the need for much more M2M communication which will almost certainly require dedicated networks and spectrum if the integrity of the operations of these critical networks is not to be compromised.

The Socio-economic value of spectrum in providing utility services to support their operations

In 2011, JRC conducted a socio-economic study of the use of radio spectrum in supporting utility operations . The report examined the economic value and the additional value to society of incorporating advanced telecommunications into a previously largely passive grid. The “additional value to society” refers to a number of non-marketable benefits which, although not creating wealth, are valued by society. The report concluded that the socio-economic value of a reliable electricity supply is at least 50-150 times the retail price of the electricity supplied.
The original report was based largely on historic data covering a period of some 35 years during which time western societies have become increasingly dependent on a reliable supply of electricity to support their standard of living. This new report follows up the previous work and applies further analysis, looking at the value of spectrum use to customers, utilities and society as a whole using more recent data.

Economic Analysis of Spectrum Pricing in the light of auction results in the first ten years

The very high prices achieved by spectrum when auctions were first introduced was an aberration. It is unlikely such high prices will be seen again in the future.
Auction conditions are a major determining factor in the prices achieved. Where a government has sought to set conditions to favour new entrants in order to stimulate competition, the prices have been lower than where existing operators have not had limits imposed.

The Socio-Economic Value of Radio Spectrum used by Utilities in support of their operations

The purpose of this study was to investigate whether there might be an element of socio-economic value attributable to radio spectrum deployed by utilities in the conduct of their business; and if this is the case, to place an indication of the amount of socio-economic value which might thus be overlooked if an award is made purely on the basis of the economic value of the radio spectrum to the utilities concerned.

Response to EC Consultation

JRC has responded to an EC Consultation on the use of spectrum for more efficient energy production and distribution.

Response to Ofcom Draft Annual Plan 2011-12

Response by JRC Ltd to the Ofcom Draft Annual Plan 2011/12. Response by JRC Ltd to the Ofcom Draft Annual Plan 2011/12. Response by JRC Ltd to the Ofcom Draft Annual Plan 2011/12. Response by JRC Ltd to the Ofcom Draft Annual Plan 2011/12. Response by JRC Ltd to the Ofcom Draft Annual Plan 2011/12. Response by JRC Ltd to the Ofcom Draft Annual Plan 2011/12

Response to DCG consultation on WAN Services Oct 2010

JRC Response to DCG consultation on WAN Services (22nd October 2010)

Response to Ofgem Smart Metering Implementation Programme Sept 2010

JRC Response to Ofgem Smart Metering Implementation Programme Prospectus (24th September 2010)

Response to Ofcom Spectrum Pricing Review, June 2010

JRC Response to Ofcom Review of Spectrum Pricing (22nd June 2010)

Parliamentary Briefing on Digital Economy Bill, Jan 2010

JRC briefing to Lords on Digital Economy Bill - 5th January 2010. JRC supports the amendment proposed by the Federation of Communication Services (FCS) at end Page 19, Line 24 (as detailed below)...

FCS Briefing on Digital Economy Bill, Dec 2009

- FCS supports the Bill overall and encourages Parliament to scrutinise it fairly and
bring it into law
- The Bill recognises the utility nature of electronic communications; competition in
services and innovation will be driven by access to the networks; FCS supports
reporting on network access
- Ensure that the UK’s Critical National Infrastructure can have certain access to radio
spectrum by including a further clause in the bill
- Ofcom should report on itself on how it provides access to radio spectrum

Response to Ofcom Consultation on Simplifying Spectrum Trading, Dec 2009

JRC Response to the Ofcom Consultation on Simplifying Spectrum Trading.(Closed 01 December 2009)

Response to BIS Consultation on new duties for Ofcom on Resilience

JRC Response to BIS Consultation on new duties for Ofcom on Resilience (October 2009)

Response to Ofcom Consultation on 'Implementing the Environmental Information Regulations 2004' Oct 2009

JRC Response to the Ofcom Consultation on 'Implementing the Environmental Information Regulations 2004.' (October 2009)

Response to the DECC Consultation on Smart Metering, Aug 2009

JRC Response to the DECC Consultation on Smart Metering (01 August 2009)

Response to the Ofcom Digital Britain Report, March 2009

JRC Response to the Ofcom Digital Britain Report (March 2009)