Spectrum - Culture, Media and Sport Committee Contents

Written evidence submitted by Barry McKeown, Datod Ltd


1.  Response to Terms of Reference issues.

2.  Other relevant matters arising.

3.  Supplementary relevant Datod published information.

4.  Contact Details.

5.  References.

6.  Appendix.


1.1  Whether the proposed method of spectrum allocation promotes, or hinders, competition in the provision of mobile broadband services

1.  Datod Response: The nature of the Electromagnetic Spectrum, inherently a mathematical model, being auction to the highest bidder permits scope for abuse of market dominance to arise by directly prohibiting innovative technology companies, who make technical breakthroughs, accessing the spectrum for the duration of the License, which in the case of 3G are for 20 years, without the consent of both the Licensee and OFCOM.

1.2  Whether the upcoming auction can provide value for money for tax payers and how that should be balanced with benefits for consumers

1.  Datod Response: Tax payers are consumers. Auctions inherently involve an abdication of responsibility. So the current arrangements do not provide best value for the tax payer who would be better served by a floating revenue charge based on the actual data traffic content application the customer (individual or business) is undertaking. This would necessarily involve a new tax regime.

2.  Customers would be further served by the intended Auction Fees instead being spent on a more rapid roll out on infrastructure.

3.  Fundamentally this situation arose due to the inability to foresee what actual services would be provided through direct transmission of data traffic compared with envisioned voice or video traffic, circa 2,000, when in the then jargon no "killer app" was identified.

4.  This lack of foresight is not the case today.

1.3  The potential for next generation mobile internet services offered by the forthcoming availability of spectrum

1.  Datod Response: It has been stated that 1G was built on voice, 2G was built on pornography and 3G on business traffic. Datod believes 4G will be built on mobile healthcare services. This new world wide industry has also been recognised by the GSMA World Mobile Congress, when the industry met in Barcelona this February. It established a supplementary forum, the mobile Health Summit, which is meeting in Cape Town, this July, to chart the way forward. It is the recognition of this market potential and the benefits to society, now, that shall enable an appropriate regulatory framework to be enacted. We note that this is not one of the five legacy issues raised with you by the Secretary of State.

2.  The Datod view is that OFCOM is an obstacle to enabling this mobile healthcare industry being established in the UK and the UK becoming a leading global player to the detriment of the economic well being of the UK. The issues are dedicated spectrum and Net Neutrality.

1.4  Whether the upcoming auction can deliver improved mobile broadband coverage in rural areas, as well as cities

1.  Datod Response: No. The auction in itself and the apportioning off coverage either by people or geography to 95% or 97% is inherently exclusive.

2.  The proffered OFCOM argument that the use of a lower frequency enables greater propagation range, while true, is misleading if actual transmitted power levels are not complementary maintained by changing technology and transmission standards. This is to misunderstand the limitations of the propagation models.

3.  This is a technology platform, from smart device to smart device, delivery issue. Whereby a change to a regulatory regime permitting the network operators and communication companies being enabled to provide, in the License mix, a multiple of delivery mechanisms through adopting converged wireless, fixed line, satellite and future High Altitude Stratospheric Platform Stations (HAPS) pipelines can ensure that 100% coverage of both people and geography is attained, seamlessly, from smart device to smart device. One issue is to appreciate how the introduction of upgraded Internet Protocols, such as IPv6, shall facilitate such capability.

4.  The key issues are safety critical applications and combating vested interests of the current stakeholders in fixed line and satellite infrastructure and in the healthcare infrastructure.

1.5  Whether license fees for mobile operators have previously been set at appropriate levels, and how this should be assessed

1.  Datod Response: Absolutely not. Witness the statements by Richards/Bowe before you from 3 May on The Work of OFCOM as to how the current liberation of the 2G spectrum to enable higher valued 3G services is being mismanaged by OFCOM.

2.  Historically, the UK 3G auction raised £22 billion for a 20 year License. This simple established monetary fact may be used as a benchmark for a true financial evaluation of the current commercial services provided by enabling a simple transposition of this actual price paid for the initial 3G spectrum amortized over the remaining period of the License less the 2G fee paid by the liberated network operators. The future auction fees attainable for 4G services are a red herring as these 3G services are being delivered now.

3.  Provision for a comparison incorporating actual revenues accrued and not tax planning arrangements should be established.

4.  It is foolhardy of OFCOM to assume 4G services shall be similar to 3G services and thus of a similar commercial value.

1.6  How the position of the UK compares with other countries, with regards to allocation and utilisation of mobile broadband spectrum

1.  Datod Response: We are at a disadvantage due to the Communications Act 2003 and OFCOM's culture and practise. OFCOM should not be compared with the EU as OFCOM prefers but instead with the US. Inherently OFCOM has a conflict of interest between regulation and technical innovation and pursuing breakthrough research, which should not be confused with risk. In the US these remits are separated between the FCC and the NTIA. Whereas OFCOM consults and deliberates, the NTIA acts. Witness that during the US 4G 800MHz spectrum auction, begun in January 2008 by the FCC and raising $19 billion, the NTIA concurrently initiated a Spectrum Sharing Innovation Test Bed for developing Dynamic Spectrum Access technology adopting Spectrum Sensing techniques. Witness also the NTIA process underway for making available an extra 500MHz of spectrum.

1.7  The possible impact on alternative uses for spectrum

1.  Datod Response; The strategic key issue is ensuring that mobile healthcare, both infrastructure and services, are available to the NHS, to enable best value to the tax payer to be attained. This issue should not be left to the mercy of the network operators to deliver. Putting it simply; with an ageing population we cannot provide millions of extra hospital or care beds so therefore mobile healthcare shall have to take the strain.

2.  The foresight issue is in establishing the worst case real time spectrum bandwidth application, for this we turn to the opposite end of the age spectrum.

3.  In appendix A are two scanned pages extracted from Professor Stuart Campbell's book "Watch me grow" on ultrasound imaging. The key statement from the Behaviour Patterns section is: "For about 10% of the time the foetus is "awake" when there will be continuous movements of the body and limbs, the eyes will be moving and the heart-rate will be fast. It is during this time that the face of the baby will be very expressive and yawning, blinking and sucking will occur". This occurs from week 31 till tem and equates to roughly three hours of bonding activity per day or 100 hours till birth. In February the US FDA approved the first 2D (slice) ultrasound smart-phone. However, for such an application to come to fruition shall require wearable device technology broadcasting into the cloud and back to the user specified display on either a 3G or 4G smart device. The issue OFCOM has failed to address is what bandwidth is required for the uplink of 3D raw real time unprocessed volumetric data instead of processed downlink video images.

4.  Such an application shall raise cultural and philosophical issues as to when human life begins to the wider public consciousness.


1.  The latest OFCOM commissioned research into technology enhancements that 4G shall bring was published on the 12 May. An extract from their web site summarises the key findings thus

"4G mobile technologies will be able to send more information than 3G, for a given amount of spectrum. This increased efficiency means that 4G networks will be able to support increased data rates and more users. The research that we commissioned indicates that early 4G mobile networks with standard configurations will be 3.3 times (230%) more spectrally efficient than today's standard 3G networks. To put this in context, a user on an early 4G network will be able to download a video in around a third of the time it takes today on a 3G network. It is anticipated that this efficiency will increase to approximately 5.5 times (450%) by 2020." and

"The research revealed that the capacity gain from the increased spectral efficiency of 4G technologies will not on its own be sufficient to meet the expected growth in demand for mobile data. As well as using existing spectrum more efficiently, more spectrum itself is also needed, some of which will be gained from the auction of new spectrum at 800 MHz and 2.6 GHz in 2012—the largest ever single auction of additional spectrum for mobile services in the UK, equivalent to three quarters of the mobile spectrum in use today.

Finally, mobile networks will also need to be designed intelligently to ensure the best use of spectrum. In particular, the research anticipates a greater use of small cells to meet demand in specific areas."

2.  However, this OFCOM position fails to take into consideration the consequences of breakthrough technologies emerging.

3.  Accordingly, we present a Technical Challenge for the Select Committee to consider bring to the attention of OFCOM in order to determine OFCOM's technical competence. The attached Excel file contains a string of numbers comprising 1,000 samples of time domain data representing baseband spectrum composed from 11 non-integer spectral components.

4.  The issue to ascertain is can OFCOM provide you with an accurate estimation of the spectral component parameters (amplitude, frequency and phase) to two decimal places. The ability of Spectrum Sensing technology to achieve this seemingly simple technical feat will provide the basis for the enabling signal processing technology to deliver a capacity gain of 100 times to be achieved. Please note that experts at both the NTIA and Stanford University (Stanford is Silicon Valley) were provided with a similar exercise and also a far harder technical challenge which both institutions failed. The test provided is for OFCOM alone.

5.  What is at stake is the technical ability to process fractional or non-integer frequencies. Current spectrum processing is based on periodic or integer frequencies. ie 1,2,3,4, etc cycles per second completed over the Observation Interval. Spectrum processing of non-integer based ie 2.1, 2.2, 2.3, 2.4, 2.5, 2.6, 2.7, 2.8, 2.9, 3.0 cycles per second over the Observation Interval shall enable a 10 times capacity gain and processing 2.10, 2.11, 2.13, 2.14, 2.15 etc cycles per second shall enable a 100 times capacity gain over existing techniques to be engineered.

6.  In the following figure is graphed the Datod Test Signal data form the attached data file with the preferred technology the NTIA considers state-of-the art applied for spectrum estimation.

Datod Test Signal



folio 6.eps

The green lines coincide with the actual spectral frequencies in the attached data file.

7.  If OFCOM cannot accurately identify these spectral components the issue they shall have to explain to you is why not and hence not just the system engineering consequences that such a technical capability shall bring but also the economic consequences.

8.  The correct parametric answers with the background information leading to this development shall be published in a forthcoming Electronics World magazine article. The far harder exercises are as yet to be presented to the readership. The clear cut issue is that if OFCOM don't understand the technical problem presented they cannot be part of the solution; as there is still some way to go to engineer a communication system.


The following Datod published articles in Electronics World magazine are relevant:

(a)  The Spectrum Anomaly: Volume 116 Issue 1892 August 2010.

(b)  Net Neutrality and a New Communications Act: Volume 117 issue 1898 February 2011.

Copies of both Electronics World magazines are being forwarded by post for consideration.


(a)  The Spectrum Anomaly: Electronics World Volume 116 Issue 1892 August 2010

(b)  Net Neutrality and a New Communications Act: Electronics World Volume 117 issue 1898 February 2011

(c)  Health and Well-Being in the Home: A Global Analysis of Needs, Expectations, and priorities for Home Health Care Technology: Commissioned by Philips and conducted by the RAND Corporation. The report is available at www.rand.org/pubs/occasional_papers/OP323.html

(d)  FCC: Chairman Julius Genachowski, Remarks as prepared for delivery: The Cloud: Unleashing Global Opportunities: March 24 2011 : www.fcc.gov

(e)  NTIA: The Spectrum Sharing Innovation Test-Bed Pilot Program Fiscal Year 2010 Progress Report: Lawrence E. Strickling, Assistant Secretary for Communications and Information: March 2011: www.ntia.gov

(f)  NTIA: Plan and Timetable to make available 500MHz of Spectrum for Wireless Broadband: Gary Locke, Secretary and : Lawrence E. Strickling, Assistant Secretary for Communications and Information: October 2010: www.ntia.gov

(g)  NTIA: Radio Spectrum Estimates Using Windowed Data and the Discrete Fourier Transform: NTIA Technical Report TR-10-470 by Roger Dalke : September 2010

(h)  OFCOM: The latest OFCOM commissioned survey into potential 4G spectrum technology:

The reports are available at: http://stakeholders.ofcom.org.uk/market-data-research/technology-research/2011/4G-Capacity-Gains/

(i)  First FDA approved Ultrasound Smartphone details are at: http://www.mobilehealthnews.com/10165/fda-approves-mobisantes-smartphone-ultrasound/

(j)  Wearable device technology: web searchable keywords: E-Textiles, Smart shirt


The following two scanned pages are extracted from Professor Stuart Campbell's book "Watch me grow" ISBN 9781-903258-85-5 and provide the relevant information.[1]


1   Ev not printed. Back

previous page contents next page

© Parliamentary copyright 2011
Prepared 3 November 2011