Written evidence submitted by BSkyB
1. This submission presents the views of British
Sky Broadcasting plc ("Sky") to the Culture, Media and
Sport Committee's inquiry into spectrum allocation.
2. In the past few months, Ofcom has issued a
number of important consultations. In addition to the auctions
of 800MHz and 2.6GHz spectrum, Ofcom is considering how best to
approach the use of spectrum in the 470MHz-792MHz band, both national
and geographic lots of interleaved spectrum.
3. Sky has engaged with Ofcom in this process,
and is now keen to contribute to the CMS Committee's inquiry to
explain the new and exciting uses for spectrum, which we believe
can be a real driver of economic growth.[53]
4. In summary, we urge legislators and policy-makers
provide for flexibility that will allow spectrum to be used by
emerging technologies which will contribute to economic growth.
5. Technological developments and digital switchover
mean that spectrum in the 470Mhz-792Mhz (UHF) bands will increasingly
become available. Ofcom has identified a range of policy drivers
for ascertaining the best use of this spectrum. We believe that
an overall policy objective should be to secure the most creative
uses for spectrum that will best drive economic growth.
6. We further believe that this policy objective
can best be achieved by realising the benefits of wireless broadband
services (implemented as "Wi-Fi"). In our submission
to Ofcom we set out the consumer and economic benefits of Wi-Fi,
and why spectrum should be allocated to this technology.
7. In summary, Wi-Fi operates on open standards
technologies and unlicensed spectrum which encourages fierce competition
to bring products and services to market in the fastest time to
meet customer demand. Wi-Fi standards are currently being updated
for UHF operation.
8. The spectacular growth of devices with Wi-Fi
inbuilt[54]
has demonstrated that open standards technologies and unlicensed
spectrum have a considerable role to play in the delivery of mobile/roaming
services to an increasing number of handheld devices in the market.
9. One of the reasons for the growth in demand
for Wi-Fi devices is that they offer consumers a lower-cost alternative
to 3G technology which generally involves follow-on costs, such
as monthly data charges, in addition to the purchase of equipment.
In terms of public Wi-Fi services, Wi-Fi already accounts for
over 20% of iPhone data traffic in the US by offloading from 3G
networks.
10. Wi-Fi is also supporting new user applications
with higher data traffic demands which are unsustainable over
3G in high population density areas, such as streaming video.
Wi-Fi is also increasingly being used in the US as a means of
providing low cost calls using VOIP application with T-Mobile
reporting that five million of its 34 million subscribers routing
calls over Wi-Fi. In the US Wi-Fi offload is widely used by AT&T,
T-Mobile, Cablevision, Metro-PCS as a key element of their data
network.
11. We believe that with the growing demand for
broadband connectivity outside the home, and the increasing problems
of congestion and interference in licence-exempt Wi-Fi spectrum
(at 2.4GHz) Ofcom should be looking to secure sufficient UHF spectrum
to ensure that this demand can be met.
12. UHF is particularly attractive for broadband
data services because it has far improved propagation characteristics
compared to both existing Wi-Fi bands at 2.4GHz and 5GHz.
13. Ofcom's approach to the release of this spectrum
should be designed to maximise the potential uses for this spectrum.
In particular, Ofcom should avoid placing unnecessary technical
constraints on its use.
14. Two such restrictions that are being contemplated
are limitations on the ability for spectrum to be freely traded,
and the imposition of unnecessary blanket technical constraints
surrounding the protection of DTT bandwidth. We believe that either
of these limitations would constrain the economic potential being
fully realised from this valuable UHF spectrum.
June 2011
53 Wi-Fi usage in the home may be generating anywhere
between $4.3 and $12.6 billion in annual economic value for consumers
in the United States "The economic value generated by current
and future allocations of unlicensed spectrum", Perspective
Associates, September 2009. http://www.ingeniousmedia.co.uk/websitefiles/Value_of_unlicensed_-_website_-_FINAL.pdf Back
54
there are approx. 5 billion Wi-Fi enabled devices worldwide, a
figure which is forecast to grow annually by 20% to 2013 Back
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