1. “Short range, high data rate, nomadic equipment operating in the frequency range 5.150 to 5.875 GHz” - BT’s Response to the Consultation Document Johnny Dixon  BT Group Technology

2. Overview BT believe that there is a need for both public & private RLAN systems in the 5 GHz bands BT believe that the bands should be used primarily by HIPERLAN 2 & IEEE802.11a How should the spectrum be best used to support all applications and technologies?

3. Public Access Systems BT believe that there is a demand for low power public access systems in these bands This would allow public access to a data network using the HIPERLAN interface This would be a pico-cellular network in major urban centres, and other locations where there are high public densities

4. Private in-home systems BT believe there will be demand for two types of private wireless home network to extend or replace wired networks –The Home Local Network (based on IEEE 1394) for interconnection of digital TV STBs with other devices in the home –The Home Access Network will interconnect with broadband interactive services delivered using ADSL, cable, MVDS etc

5. Private business systems BT believe that there will be a large demand for private RLANs for businesses These will typically be operated in: –offices –industrial sites –large business sites … and will give employees nomadic / cordless access within the business premises

6. The RA’s Proposals BT’s response to the “Strawman”

7. 1) IEEE 802.11a be permitted to operate in these bands Yes, BT support the introduction of IEEE 802.11a in these bands –Co-existence with HIPERLAN 2 should not be a problem –This will enable an easier migration from the 2.4 GHz band to the 5 GHz band

8. 2) HIPERLAN 0 is excluded BT believe that the primary reason for introducing “HIPERLAN 0” would be to enable IEEE 802.11a We do not support the development of “UK only” variants, but support harmonisation Therefore, we support: –acceptance of IEEE 802.11a –rejection of HIPERLAN 0

9. 3) Band Partitioning plan BT support the proposed band partition, except for: –We believe that HIPERLAN 2 & IEEE 802.11a should also be able to use 5150 - 5250 MHz –We propose that licensed (public access) systems should be located at the lower end of the 5470 - 5725 MHz band

10. 4) Licensing and regulation issues should follow from the partitioning of the band Any partitioning of the band will define the licensing and regulation requirements However band partitioning should be limited to the minimum required Similarly, licensing and regulation should also be minimised

11. 5) Licence exempt spectrum for private networks should remain Certainly - Private networks using licence exempt spectrum was the original intention This is likely to remain the main market for RLANs However, in addition there are now new requirements (including public access)

12. 6) Band partitioning is the key issue Definitely! How can we make best use of the available spectrum, taking account of: –the needs of the varying applications of RLANs –the various types of RLANs –the restrictions placed by the other users of the bands

13. Questions to be considered BT propose that the following questions be considered before a decision is made on spectrum partitioning between public and private systems: What would be the relative demands for the two systems? How close (geographically) would public and private systems typically be located?

14. Would it be possible for public and private access systems to share a given frequency band (e.g. 5470 - 5650 MHz) if one of the systems operate at a lower EIRP in that band? Would it be possible to offer a satisfactory quality of service for a public service in a shared band? Would it be possible to obtain European wide agreement for part of the band to be used on a public access only basis?

15. In conclusion BT believe that there is a need for both public & private RLAN systems in the 5 GHz bands BT believe that the bands should be used primarily by HIPERLAN 2 & IEEE802.11a How should the spectrum be best used to support both applications and technologies?