European Forum for Spectrum Coexistence (EFSC)

White Paper

COEXISTENCE: THE MISSING ELEMENT IN CURRENT SPECTRUM POLICY

Version 1.0

Date: June 19th, 2012

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Overview: Coexistence for an improved EU spectrum policy

The European Forum for Spectrum Coexistence supports the European Commissions objectives shared by Member States to harmonize conditions regarding the availability and efficient use of the radio spectrum in the EU. This represents an important component of the wider policy initiative called the Digital Agenda and the first Radio Spectrum Policy Programme which was launched by Commissioner Kroes to deliver sustainable economic, social and cultural benefits from Europes digital single market. But without coexistence among all components of the electromagnetic ecosystem as a key tenet written into EU rules and regulations, which impact Member States and their citizens, these worthy policy objectives will struggle to become reality. Europe has witnessed a veritable explosion in usage of digital devices in recent times and European policy makers have recognized the importance of the ubiquitous connectivity offered by the wider ICT industry for both business and consumers. As a result, the increasing number and variety of radio services has also increased the complexity of spectrum policy coordination across Member States. This poses a challenge for coexistence between equipment and services for both consumers and businesses. The European electromagnetic environment is constantly evolving and requires careful consideration. Thorough impact assessments and fair consultation involving all stakeholders should lead to adapted policy making processes that are needed to ensure ongoing compatibility between new and existing devices and services and to avoid, potential interruption of service due to unwanted interference. European consumer electronic producers, cable and satellite reception equipment industry, the broad cultural sector, content making industry and cable operators are all raising this issue to ensure that radio spectrum allocation and related policy take into account deployed radio and non-radio electronic equipment. Given the wide set of stakeholders, it is critical for Europe to promote quality connectivity of products and services for consumers and business.

2 Objective: Coexistence as a driver for growth and innovation

The objective of this initiative is to promote coexistence as a means to furthering Europes economy and culture. There is recognition that in order to achieve the Digital Agenda targets it is paramount to preserve the competitiveness of all stakeholders, foster growth and innovation while at the same time continuing to improve European spectrum efficiency. The European Forum for Spectrum Coexistence is concerned that the current EU process for radio spectrum allocation fails to take full account of the complexity of the entire electromagnetic ecosystem. In particular there is not enough consideration given to the coexistence of electronic equipment in the rapidly changing radio environment despite its compliance with current EU standards relevant to demonstrate conformity with the R&TTE and EMC Directives. The political decisions to introduce new radio services appear to be based on incomplete technical assessments leading to uncertainty for consumers and businesses alike. Coexistence needs to be built from the outset of the radio spectrum allocation process in order for Europe to fully benefit from growth and innovation of both existing and new services.

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3 Context: A need for a more inclusive EU spectrum policy

Today there is a very competitive landscape for electronic products. Innovation is taking place at an increasing rate and technology changes at a dizzying pace. All users expect reliable and available connectivity to services to follow them wherever they are at home or abroad. This has created a complex and changing technology environment where devices and services need to keep coexisting if business and consumers wish to avoid unwanted interruption. Unfortunately, when defining the technical conditions for the introduction of new radio services, the current radio allocation process does not take into consideration the operating parameters of other communication services that are defined by EU standards and built into existing equipment in order to establish an electromagnetic environment allowing seamless coexistence of services. This means that new equipment risks interfering with existing equipment and services the very existing equipment and services which comply legally with current standards. With a fast-changing radio environment amplified by the opportunities provided by the Digital Dividend, such a shortfall in the process is becoming apparent and could lead to an increasing number of interference issues being raised not only between radio services but also with existing equipment and other non-radio services. As an example, when the 800MHz band was allocated to electronic communication services, the CEPT report 30 [1] failed to take into account the Electromagnetic Compatibility (EMC) standards for electronic equipment already deployed in the European market. Furthermore, the electromagnetic coexistence of wireless production tools were not sufficiently addressed [X]. As a result, it is unclear if these equipments are able to coexist with new services. In particular, concerns were raised that incompatibility would lead to severe disturbance of many services such as television, Internet, telephony, and live entertainment. As of today no satisfactory solution has been proposed apart from replacing consumers equipment in case disturbances occur. More recently, in the context of the deployment of White Space Devices, CEPT was asked to specifically consider the protection of Cable services. While the potential issue was recognized by CEPT, it declined to work on it arguing that CEPTs scope was limited to the protection of radio services [2]. As a result, the recently published ECC report 159 [3] fails to ensure coexistence of White Space Devices within the ecosystem of electronic equipment and services deployed today. These issues raises just one instance of potential disturbance yet is particularly worrying for the wider set of stakeholders working within the European Forum for Spectrum Coexistence. One particular worry is that European Harmonised Standards are not fulfilling their role in reassuring consumers and businesses that it is safe to keep investing in consumer electronic equipment. Indeed, European Standards are potentially becoming irrelevant as they seem not to be given proper consideration in the radio spectrum allocation process. Consumers and businesses need long lasting equipment that will keep working during the product lifetime. We should encourage a green environment society where consumer and business investments would not be undermined by shortsighted and uninformed decisions. In addition of the failure to take into account operating conditions of existing services and equipment when performing technical assessments of new radio services, the current institutions managing the radio allocation process are often not allowing a fair representation of all stakeholders. Different industry sizes make it difficult for some stakeholders to be represented in all the institutions at national or international level. Furthermore, the terms of reference under which they operate often limit inappropriately their scope of activities making it harder for this issue to be taken into account. Design improvement and product replacement could create unfair and unexpected cost to consumers and businesses. There is a commercial dimension to this issue that needs to be addressed from the outset of the spectrum allocation discussions. This is why the European Forum for Spectrum Coexistence believes that the solution to this issue has to be political.

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4 Finding ways to ensure coexistence

There is a need to future proof the process for radio spectrum allocation. It should be revised in order to be aligned with the current pace of technology developments such that new radio services cannot be introduced without due diligence on the equipment and services already deployed. In this context, we strongly recommend an enhanced coordinating role from the European Commission with the aim of ensuring fairness and efficiency in close cooperation with Member States for a smooth functioning of the internal market. The complexity of the new ICT environment will necessitate more fluid and cohesive management from the European Commission and put it on the global agenda. The European Commission needs to ensure spectrum efficiency while at the same time providing Member States with a comprehensive impact assessment including economical, technical, cultural and social aspects to serve as the basis for the political decisions to introduce new radio services. Such mechanisms that take into account the entire electromagnetic ecosystem are currently not in place. They need to be established and applied as a matter of urgency as we see already new services such as White Space Devices being introduced in Europe. At the same time, it is important to improve the coordination between DG CONNECT and DG ENTR in these matters and seek input from DG EAC given the wider cultural dimension when considering the disruption of content production equipment, viewing equipment and distribution platforms. Such improved governance would ensure that all interests are duly reflected and taken into account. The technical parameters for new radio services should be established in such a way that impact on existing radio and non radio services and equipment will be avoided. The extent of such impact needs to be fully assessed from the outset of the radio spectrum allocation process. The European Forum for Spectrum Coexistence believes that it should be the task of the organizations defining the operating conditions for new radio services (including CEPT) to take into account all parameters for coexistence with radio and non-radio services and equipments in close cooperation with European Standards Organization such as ETSI and CENELEC. Otherwise, European Harmonised Standards are not fulfilling their role in reassuring consumers and businesses that it is safe to keep investing in innovative services and equipments. European Standards will become irrelevant if they are not given proper consideration in the radio spectrum allocation process.

5 Conclusion
The European Forum for Spectrum Coexistence calls upon decision makers to identify clear responsibilities between parties and to ensure that deployed equipment and services, both radio and non-radio, will be taken into account when defining new radio services. If these new services imply a change in the electromagnetic ecosystem then efficient
mitigating measures of disturbance to existing services and specific funds should be set up to accommodate the possible need for adaptation of equipment to the new environment. Consumers and businesses potentially affected should not become victims of mismanaged spectrum allocations.

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Notes:
European Harmonised standards listed against the current EMC and R&TTE Directives are meant to ensure that equipments are designed and

manufactured with a level of immunity to the electromagnetic disturbance to be expected in its intended use which allows it to operate without unacceptable degradation of its intended use[4]. New radio services have the potential to change the electromagnetic disturbance for these
equipments therefore this impact should be studied and taken into account from the very outset of establishing the technical parameters for the new radio services. Unfortunately this isnt happening with current spectrum allocation process.

References:
[1] http://www.erodocdb.dk/docs/doc98/official/pdf/CEPTRep030.pdf The report mainly studied the interference from PMSE into IMT/LTE and forgot to make a severe study on the impact of IMT/LTE on PMSE. The study used only models derived from assumptions on IMT/LTE based on UMTS modulation schemes. The models were also designed to accommodate LTE with the least conditions and high margins for interference into Digital Terrestrial Television and PMSE. Current studies and measurements show that LTE will create much more spurious than UMTS with the result the SRD band (863-870MHz) will be interfered dramatically by LTE User Equipment. The Duplex Centre Gap (821-832MHz) in future to be used by radio microphones will also be interfered and in best case only 3 till 4 MHz of the band can be used. Aggregated effects of LTE user equipment was not considered at all. The APWPT participated in the CEPT meetings related to this report and asked many times for real equipment measurements which did not take place since as the IMT industry was not willing to cooperate. The impact on cable systems was also introduced by Cable Europe but was considered to be an EMC issue and therefore ignored. [2] See ECC meeting report document ECC(11)027 and liaison to ETSI in Annex 13:
It should be noted that the Report does not address the potential impacts of cognitive radio systems on cable services since the ECC considers this matter as an EMC subject. Thus, it should be handled in the European fora relevant for such subject (e. g. CENELEC and ETSI).

[3] http://www.erodocdb.dk/docs/doc98/official/Pdf/ECCRep159.pdf [4] Essential requirements in article 5 of Directive 204/108/EC Annex I http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2004:390:0024:0037:en:PDF

About the EFSC:

The European Forum for Spectrum Coexistence aims at preserving the coexistence between devices and services when new radio services are introduced. Its mission is to collectively ensure that any radio spectrum allocation and related policy take into account deployed radio and non-radio electronic equipment in order to promote quality connectivity of products and services for European consumers and busi ness. The European Forum for Spectrum Coexistence is an open group composed of many stakeholders ranging from equipment manufacturers to service providers and live performance associations. Active participants currently include: APWPT, CABLE EUROPE, ZVEI, PEARLE, Kathrein, Panasonic Europe, TPV, SES.