Carsten Ullrich Commercial Registry: Amtsgericht Köln HRB 57962

Managing Director: Carsten Ullrich Commercial Registry: Amtsgericht Köln HRB 57962

Inquam Broadband Responses
Question 1: What is your opinion on PTS's proposal to award the
frequency bands 1900 – 1905 and 2500 – 2690 MHz during the first
six months of 2008?
The Inquam Broadband Response: Inquam Broadband fully
supports the award of the 1900 – 1905 MHz and 2500 – 2690 MHz
spectrum at the earliest opportunity.
Question 2: What is your opinion on PTS's proposal to award
national licences in the frequency bands 1900 – 1905 and 2500 –
2690 MHz?
The Inquam Broadband Response: Inquam Broadband supports
PTS’s proposal to award national licences in both frequency bands.
Question 3: What is your opinion on PTS's proposal to award:
a) Technology and service neutral licences in the 2500 – 2690 MHz
band, and
b) 1900 – 1905 MHz for UMTS–TDD?
The Inquam Broadband Response:
Part a): Inquam Broadband fully agrees that licence awards should
remain both technology neutral and service neutral in the 2500 –
2690 MHz band.
The 2.6 GHz band is widely available for Broadband Wireless Access
(BWA). Within Europe, the UK, Norway, Italy and Belgium have either
recently consulted or are currently consulting on a technology and
service neutral approach.
Opening the band for use by state-of-the-art technologies will
enhance the opportunity to support technical innovation, to stimulate
competition and to allow market demand for broadband services to
be satisfied for the benefit of Swedish customers.
Part b): Inquam Broadband supports service and technology neutral
attribution in all bands. Market requirements should decide about the
best fit of technology to the customer demand.
Page 2 of 6

Question 4: What is your opinion on PTS's proposal to award:
a) 2570 – 2620 MHz for TDD, and
b) 2500 – 2570 and 2620 – 2690 MHz for FDD uplink and downlink?
Inquam Broadband Response:
Part a) Inquam Broadband believes that there will be strong demand
for TDD operation in this band if this spectrum is assigned in a
technology neutral manner.
The TDD mode is more suitable to account for asymmetric traffic
applications i.e. imbalanced requirements for up- and downlink. The
latter applies to many applications and since the uplink and downlink
ratio can be changed easily, TDD systems are able to achieve higher
spectrum efficiency.
Given this anticipated demand for TDD applications, Inquam
Broadband believes that the proposed FDD allocation is too large
relative to the TDD allocation. Inquam Broadband would prefer to let
market forces decide whether the attribution shall be a paired or
unpaired spectrum. In this context see also Inquam Broadband’s
response to Question 4 b) below.
Part b) As already mentioned above in response to Question 4 a),
Inquam Broadband would prefer to let the market decide whether the
attribution shall be paired or unpaired. One possible solution is not to
decide a split beforehand, but to design the awarding procedure in a
way which allows the bidders to bid for either unpaired or paired
spectrum (as suggested by the UK for instance, see [1]).
In this context it is also very important to have full tradability of the
awarded spectrum. Furthermore, the operators should have a right to
change the usage conditions (i.e. usage of TDD technology in paired
bands) or a right of mutual coordination with other spectrum owners
(e.g. for spectrum swaps).
Question 5: What is your opinion on PTS's proposal to award:
a) One licence (5 MHz) in the 1900 – 1905 MHz band (UMTS–TDD)
b) One licence (50 MHz) in the 2570 – 2620 MHz band (TDD)
c) 14 paired frequency blocks each of 2×5 MHz in the 2500 – 2570
MHz and 2620 – 2690 MHz bands (FDD)?
Inquam Broadband Response: Inquam Broadband suggests
partitioning of the entire 2500 – 2690 MHz band into 5 MHz blocks
either paired or unpaired. Awarding a single unpaired licence within
2570 – 2620 MHz band does not support competition to the benefit of
the Swedish customers. In any case, the number of licences
Page 3 of 6

awarded per operator should be limited in a manner that takes into
account operators’ pre-existing spectrum assignments in the
900/1800 MHz and 2 GHz bands. Furthermore, some spectrum
should be reserved for new market entrants in order to support
competition to the benefit of the Swedish customers. See also
Inquam’s response to Question 8.
Question 6: What is your opinion on PTS's proposal for bids in the
auction for 2500 – 2570 and 2620 – 2690 MHz to refer to a specific
2×5 MHz block?
Inquam Broadband Response: For better transparency the bids
should refer to specific 5 MHz and 2x5 MHz blocks. After assignment,
the licensees should be allowed to swap frequency blocks based on
mutual agreement.
Question 7: What is your opinion on PTS's proposal to not have rollout
or coverage obligations in the licences?
Inquam Broadband Response: Inquam Broadband is in favour of
PTS’s proposal since the Swedish customers already have a broad
choice among various networks and services. Inquam Broadband
does not believe that coverage obligations are the right measures to
ensure efficient use of the spectrum. Inquam Broadband
understands that the licensees will be operating in a competitive
environment and will have the incentive to maximize the value of their
spectrum by ensuring that they are in a better competitive position
with regard to service coverage.
Question 8: What is your opinion on PTS's proposal for a 110 MHz
spectrum cap for those applying for both FDD and TDD frequencies
in the frequency band 2500 – 2690 MHz?
Inquam Broadband Response: Inquam Broadband agrees with the
concept of a spectrum cap, but suggests an alternate approach.
First, the size of the cap should be smaller in order to allow access to
the spectrum by more operators for the benefit of Swedish
customers. Additionally the spectrum cap should take into account
the existing assignments in 900/1800 MHz and 2 GHz bands. In
accordance to the WAPECS concept, these spectrum ranges can be
treated as equivalents to the 2500 – 2690 MHz band in terms of
services. Therefore, in order to provide a level playing field and
increase competition among service providers, a more stringent
spectrum cap should be applied to the newly available spectrum.
Page 4 of 6

Second, existing mobile operators are using the same technology
platforms and therefore benefit from economies of scale for their
deployments. Additionally, they have comparable cost structures
based on their common technology platforms and thus no pressure to
innovate. They have also existing customer bases which give them a
powerful market position. The combination of these factors, leads to
a significant market distortion.
Excluding existing mobile operators would be an appropriate
approach to enable spectrum access by new entrants and would
support increased competition as well as the introduction of new
innovative products. An increase in innovation and competition will in
turn lead to improved service offerings and a decrease in prices.
Furthermore, due to an increasing competitive situation, existing
mobile operators will be driven to use their spectrum holdings more
efficiently.
At a later stage when other spectrum resources could be made
available, all successful operators should be permitted to apply for
additional spectrum, but only after consideration of an appropriate
cap on the total amount of their spectrum holdings. Such an
approach will lead to balanced market conditions for both established
operators as well as for new entrants.
Question 9: What is your opinion on PTS's proposed spectrum
masks for FDD base stations (Figures 1–3)?
Inquam Broadband Response: Inquam Broadband has no
comments on this spectrum mask.
Question 10: What is your opinion on PTS's proposed spectrum
masks for TDD base stations (Figures 4–5)?
Inquam Broadband Response: Inquam Broadband does not
support the proposed TDD BS EIRP spectrum mask definition for the
lower band edge, since it would further narrow the usable spectrum
for TDD deployments to fulfil those limits, i.e. the out-of-band limit.
An additional decrease in the amount of TDD-usable spectrum is not
reasonable given that TDD mode is more suitable to account for
asymmetric traffic scenarios which apply more and more to many
applications. From there, a strong demand for TDD operation can be
expected. Furthermore, given that the uplink and downlink ratio can
Page 5 of 6

e changed easily, TDD systems are able to achieve higher spectrum
efficiency (see also Inquam Broadband’s response to Question 4).
To sum up, coexistence between FDD and TDD should be established
based on similarly spectrum mask requirements for both on
the expense of the FDD and TDD deployments. This would be also in
line with the proposed approach to award the 2500–2690 MHz
spectrum on a technology and service neutral base (see also Inquam
Broadband’s response to Question 3).
Question 11: What is your opinion on PTS's proposed spectrum
masks for FDD and TDD terminals (Figures 6–7)?
Inquam Broadband Response: Instead of defining the terminals’
spectrum mask based on the maximum transmitter spectral power
density, Inquam Broadband suggests to define the transmitter mask
based on transmitted EIRP density. The maximum transmitted EIRP
spectral power density should set at least set to 24dBm/MHz without
any assumptions as to the FDD / TDD terminals antenna gain.
Inquam Broadband agrees with the overall shape of the terminal
spectrum mask.
Question 12: What is your opinion on PTS's proposed technical
conditions for the frequency band 1900 – 1905 MHz?
Inquam Broadband Response: Inquam Broadband has no
comments on these technical conditions.
References
[1] Award of available Spectrum: 2500 – 2690 MHz, 2010 –2025 MHz
and 2290 – 2300 MHz, OFCOM Consultation, December 2006.
Page 6 of 6