Written evidence submitted by Network
1. The railway, in common with other critical
national infrastructure, relies on high-quality, highly reliable
telecommunications. The quantity and quality of information needed
to run the network safely and efficiently is set to continue to
grow as signalling, passenger information and train management
become increasingly sophisticated to deliver the railway Britain's
2. Currently, GB mainland railway operational
communications, to train drivers and key staff, is delivered using
legacy analogue radio systems, which are gradually being replaced
by GSM-R. All of these systems are built upon a common foundation
of good quality, dedicated radio spectrum. This is however just
one system element required to deliver a mobile communication
system fit for a safety critical operational purpose. The next
generation of operational mobile communications, such as Automatic
Train Operation and In-Cab CCTV, will be characterised much increased
bandwidths, whilst maintaining the current service integrity.
3. Auctioning spectrum to commercial users makes
sense if we want to maximise government's revenues. However, requiring
providers of critical national infrastructure and the emergency
services to compete with mobile telephone operators risks either
under-providing essential spectrum, or over-paying for it.
4. Maximising income from the auction must be
set against the cost to essential public services of doing so.
Network Rail's income is made up of direct grant from government
and income from train operators, many of whom are in receipt of
public subsidy. Most other critical national infrastructure is
publically funded; forcing competition between essential public
services and commercial operators is unlikely to deliver value
5. One way to proceed would be to reserve sufficient
spectrum for critical national infrastructure. This approach has
been followed in the United States and ensures that revenue from
commercial operations is maximised and the public interest protected.
6. If this approach is not followed, in favour
of a conventional price-led auction, it is likely that critical
national infrastructures may have to buy mobile data services
from commercial operators. This would be problematic, because
the specifications of the two types of use are quite different.
The railway requires extremely reliable and high-quality communications,
well beyond what is required for mobile telephone networks. If
a mobile telephone signal is weak it is an irritation; if a train
with in-cab signalling loses contact with the control centre it
would cause significant delays to multiple trains; in the worst-case
becoming a safety risk.
7. In summary, we believe that auctioning spectrum
is appropriate for commercial users but not critical national
infrastructure or emergency services users. The different specifications
required, as well as value for money for taxpayers, mean that
to require Network Rail and others in a similar position to compete
with mobile telephone services risks under-specifying or over-paying,
or both. Reserving a proportion of the spectrum for critical national
infrastructure would enable the government to maximise revenue
from commercial operators without denying essential public services'
rather different telecommunications needs. This approach could
either be achieved through direct access to suitable spectrum,
or by applying public service commitments to some of the auctioned