Written evidence submitted by Barry McKeown,
Datod Ltd
STRUCTURE OF
SUBMISSION
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. RESPONSE TO
TERMS OF
REFERENCE ISSUES
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.
2. OTHER RELEVANT
MATTERS ARISING
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
DFT WITH FLAT-TOP WINDOW SPECTRUM
XXXXXXXXXX
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.
3. SUPPLEMENTARY
RELEVANT DATOD
PUBLISHED INFORMATION
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.
4. REFERENCES
(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
APPENDIX
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
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