asmg may 23 dubai
TRANSCRIPT
11 APRIL 2013
© GSMA 2013
WRC-15: SECURING SPECTRUM FOR MOBILE
ASMG DUBAI – 23 MAY 14
Peter Lyons, Director of Public Policy – MENA
GSMA
How Much is Enough?
SPECTRUM FOR MOBILE© GSMA 2014
AGENDA
Mobile Data Growth
Spectrum Demand
Potential Future Mobile Bands
What’s at Stake?
SPECTRUM FOR MOBILE© GSMA 2014
GSMA BY THE NUMBERS
MOBILE DATA GROWTH
SPECTRUM FOR MOBILE© GSMA 2014
A MOBILE BROADBAND REVOLUTION
Source: Mobile Economy, GSMA 2014
SPECTRUM FOR MOBILE© GSMA 2014
A MOBILE BROADBAND REVOLUTION
Source: Mobile Economy, GSMA 2014
SPECTRUM FOR MOBILE© GSMA 2014
MOBILE DATA ROCKETING
Source: Ericsson mobility report 2013
Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q40
200
400
600
800
1000
1200
1400
1600
1800
2000
Voice Data
2013 2014 2015 2016 2017
70%
qrowth in data traffic between Q4 2012
and Q4 2013
Tota
l (up
link
+ do
wnlin
k) m
onth
ly tra
ffic
(Pet
aByt
es)
SPECTRUM FOR MOBILE© GSMA 2014
For the Arab States, Broadband is MOBILE
Source : 3G Penetration (GSMA Intelligence database) Fixed Broadband Penetration (ITU)
High levels of Mobile data usage in the Arab States driven by underdeveloped fixed-line infrastructure and limited Wifi offload. Mobile Broadband Consumption to be further boosted by move from 3G to 4G and decline in cost per bitJapan 27.73%
USA 28.35%
Korea 37.25%
UAE 10.34%
Fixed BB Penetration
KSA 6.95%
EGYPT 2.80%
SPECTRUM FOR MOBILE© GSMA 2014
4G TRANSFORMS DATA USAGE4G IS CAUSING A STEP CHANGE IN AVERAGE MOBILE DATA CONSUMPTION
In Saudi Arabia, mobile traffic per user expected to reach 6.4 G-bytes per month by 2018, up from 703 MB per month in 2013, a CAGR of 55% - Cisco VNI
The average T-Mobile US subscriber on an unlimited data plan uses 5 G-bytes/mo- T-Mo US CFO Feb 2014
SPECTRUM FOR MOBILE© GSMA 2014
HOW WILL DATA USAGE CHANGE BY 2018?
In North America, mobile traffic per user will reach 9 G-Bytes per month by 2018, up from 1.4 G-bytes per month in 2013, a CAGR of 46%.
In Western Europe, mobile traffic per user will reach 4.8 G -bytes per month by 2018, up from 717 megabytes per month in 2013, a CAGR of 48%.
In Asia Pacific, mobile traffic per user will reach 2.4 G-bytes per month by 2018, up from 239 megabytes per month in 2013, a CAGR of 58%
Source : Cisco VNI
BUT WHAT DRIVES SPECTRUM DEMAND IS DATA PER SUBSCRIBER AT PEAK TIMES
SPECTRUM FOR MOBILE© GSMA 2014
RISING DATA, FALLING REVENUE PER BIT
CHINESE ACADEMY OF TELECOMMUNICATIONS RESEARCH (CATR) LOOKED AT HOW MOBILE DATA DEMAND WILL GROW ASSUMING LOWER COST PER BIT (2013)
http://www.gsma.com/spectrum/wp-content/uploads/2013/01/SOCIO-ECONOMIC-IMPACT-OF-SPECTRUM-IN-CHINA.pdf
“
From the above table it can be seen that the growth rate for data traffic is surprisingly high: Data Unit cost of 2012 is 300 Yuan, while this index declines to 7.58 Yuan in 2020; data traffic in 2015 will be 9 times as much as that in 2012; while in 2020, data traffic will be 200 times as much as that in 2012, at a compound annual growth rate as high as nearly 100%.”
Year ARPU(Yuan)
Data Unit cost(Yuan/GB)
Data Trafficper user per month (MB)
2012 65.79 300.00 53
2013 83.50 181.17 111
2014 105.98 110.82 231
2015 134.52 68.56 474
2016 170.73 44.54 925
2017 210.13 28.22 1,797
2018 250.54 17.41 3,474
2019 289.09 10.43 6,693
2020 333.56 7.58 10,629
SPECTRUM FOR MOBILE© GSMA 2014
WILL RAPID MOBILE DATA GROWTH TAIL-OFF?
IS THE REPLACEMENT OF FIXED BROADBAND NETWORKS A LOGICAL END POINT? In developing markets, lack of fixed networks means mobile networks will carry almost all data
which has a major impact on spectrum requirements
Average fixed broadband consumption in a typical Western European market Source: Analysys Mason 2013
2012 2013 2014 20150
10
20
30
40
50
60
70
80
90
Usag
e (G
B pe
r line
per
mon
th)
In Australia , fixed broadband data usage grew 62% from Q2 2012-Q2 2013 - ACMA: Communications Report 2012–13
In the UK, the average fibre (FTTC/FTTH) connection exceeded 110GB per month in 2012- Analysys Mason 2013
In North America , average monthly fixed broadband data usage reached 44.5GB per month in 2H 2013- Sandvine 2013
SPECTRUM FOR MOBILE© GSMA 2014
FIXED BROADBAND PENETRATIONFIXED BROADBAND SUBSCRIPTIONS PER 100 INHABITANTS, BY REGION, 2014*
WRC-15SPECTRUM REQUIREMENTS
SPECTRUM FOR MOBILE© GSMA 2014
WRC-15: MUST MEET LONG-TERM DEMAND
Allocations at WRC-15 won’t be licensed until 2020-2025 when data demand will be much higher
– The ITU assumes a 44-80x increase in mobile data between 2010 and 2020
Admins won’t need to license spectrum allocated at WRC-15 until they are ready
– Existing services can continue & be protected through coordination and regulatory conditions
– BUT if new bands aren’t allocated then admins will struggle to react to growing data traffic
Admins not planning to use WRC-15 bands in near-term will still benefit from lower cost equipment for their later roll-outs
– Early movers generate economies of scale so countries that deploy later benefit from cheaper smartphones and base stations etc..
– Economies of scale only generated through the identification of harmonized bands at WRC-15
SPECTRUM FOR MOBILE© GSMA 2014
SPECTRUM ESTIMATES IN CPM TEXT
User density settings
Total spectrum requirements
(MHz)
Region 1 Region 2 Region 3
Already identified (MHz)*
Additional spectrum
requirements (MHz)*
Already identified (MHz)
Additional spectrum
requirements (MHz)
Already identified (MHz)*
Additional spectrum
requirements (MHz)*
Low 1 340 981-1 181 159-359 951 389 885-1 177 163-455
High 1 960 981-1 181 779-979 951 1 009 885-1 177 783-1 075
SG 5 APPROVED REPORT M.2290-0 (12/2013)
Source : JTG Document 4-5-6-7/TEMP/142-E - 28 February 2014
Note *: The values in these columns have ranges since some of the frequency bands are identified for IMT only in some countries in Regions 1 and 3 as per RR Nos. 5.317A, 5.430A, 5.432A, 5.432B, and 5.433A.
THIS SUGGESTS A SHORTFALL OF AROUND 800 TO 900 MHZ (HIGH SCENARIO)
SPECTRUM FOR MOBILE© GSMA 2014
SPECTRUM ESTIMATE INPUTS TO WP5D
Doc. 5D/ 63 66 118 256 242 170 417
Source US Australia Russia China GSMA India UK
Estimation year Until 2014 Until 2020 2020 2015, 2020 2020 2017, 2020 2020
Spectrum requirements
Additional requirement of 275 MHz by 2014
Total requirement of 1,081 MHz(Additional requirement of 300 MHz by 2020)
Total requirement of 1,065 MHz(Additional requirement of 385 MHz by 2020)
Total requirement of 570-690 MHz (by 2015) Total requirement of 1,490-1,810 MHz (by 2020)
Total requirement of 1,600-1,800 MHz for some countries
Additional requirement of 300 MHz by 2017 Additional requirement of another 200 MHz by 2020
Total requirement of 775-1,080 MHz for the low demand setting Total requirement of 2,230-2,770 MHz for the high demand setting
MethodologyUsing an original methodology
Using an original methodology
Using an original methodology
Using the methodology in Rec. ITU-R M.1768-1
Using a new methodology to complement the methodology in Rec. ITU-R M.1768-1
Using an original methodology
Using the methodology in Rec. ITU-R M.1768-1
OTHER ESTIMATES THAT HELP BENCHMARK THESE RESULTS
SPECTRUM FOR MOBILE© GSMA 2014
GSMA SPECTRUM DEMAND MODELLING
GSMA model was developed by Coleago consulting (some results submitted to WP5D) Different from WP5D, in that it uses less complex approach based on how one might
dimension voice networks (Erlang and Busy hour with grade of service) Traffic is distributed over cells based on population density and total traffic and 12% daily
assumed in the busy hour, and based on current traffic profiles Operator site numbers (+ allowance for increase) major factor in determining the
spectrum The network is dimensioned to ensure 98% of cells can operate with no congestion in the
busy hour An element is built-in for quality of service (50%) and signalling (15%) The model then needs an input on the number of cells in a country and the area covered
GSMA MODEL DESCRIPTION
SPECTRUM FOR MOBILE© GSMA 2014
UAE DEMAND MODEL: ASSUMPTIONS
Area type Pop density Macro sites
Average cell size/ cell radius
User distrib.
Traffic distrib
Rural < 70 pop/sqkm 1,889 32.3 km2 / 3.2 km 37 % 32%
Sub urban 70-1000 pop/sqkm 2,426 5.3 km2 / 1.3 km 57 % 57%
Dense urban >1000 pop/sqkm 242 1.0 km2 / 0.6 km 6 % 11%
The cell sites are distributed according to user density with smaller cells in dense urban areas and larger cells in rural areas
KEY ASSUMPTIONS FOR 2020: 7 Million unique subscribers 4557 macro cell sites per operator 99 % population / 88% geographical coverage
SPECTRUM FOR MOBILE© GSMA 2014
UAE: DEMAND & RESULTS
The data traffic estimation per subscriber (not connection) differs according to area type and scenario
Lower Scenario Middle Scenario Higher Scenario
Area type Data per user per month
Spectrum Required
Data per user per month
Spectrum Required
Data per user per month
Spectrum Required
Rural 4.3 GB 259 MHz 8.5 GB 487 MHz 12.8 GB 720 MHz
Sub urban 5 GB 322 MHz 10 GB 619 MHz 15 GB 920 MHz
Dense urban
9.6 GB 597 MHz 19 GB 1,118 MHz 29 GB 1,699 MHz
National Average
5 GB 597 MHz 10 GB 1,118 MHz 15 GB 1,699 MHz
SPECTRUM FOR MOBILE© GSMA 2014
SAUDI ARABIA: ASSUMPTIONS
Area type Pop density Macro sites
Average cell size/ cell radius
User distrib.
Traffic distrib
Rural < 40pop/sqkm 5,636 175 km2 / 7.5 km 32 % 24%
Sub urban 40-500 pop/sqkm 7,232 19.2 km2 / 2.5 km 59 % 59%
Dense urban >500 pop/sqkm 802 3.9 km2 / 1 km 9 % 17%
KEY ASSUMPTIONS FOR 2020: 25 million unique subscribers 13,760 macro cell sites per operator 95% population / 53% geographical coverage
The cell sites are distributed according to user density with smaller cells in dense urban areas and larger cells in rural areas
SPECTRUM FOR MOBILE© GSMA 2014
SAUDI ARABIA: DEMAND & RESULTS
Lower Scenario Middle Scenario Higher Scenario
Area type Data per user per month
Spectrum Required
Data per user per month
Spectrum Required
Data per user per month
Spectrum Required
Rural 3.8 GB 250 MHz 7.5 GB 473 MHz 11 GB 698 MHz
Sub urban 5 GB 351 MHz 10 GB 678 MHz 15 GB 1006 MHz
Dense urban
9.2 GB 625 MHz 18 GB 1,226 MHz 27.5 GB 1,830 MHz
National Average
5 GB 625 MHz 10 GB 1,226 MHz 15 GB 1,830 MHz
The data traffic estimation per subscriber (not connection) differs according to area type and scenario
SPECTRUM FOR MOBILE© GSMA 2014
NIGERIA: ASSUMPTIONS
Area type Pop density Macro sites
Average cell size/ cell radius
User distrib.
Traffic distrib
Rural < 300 pop/sqkm 5,648 69 km2 / 4.7 km 42% 15%
Sub urban 300-3000 pop/sqkm 4,900 23 km2 / 2.7 km 45% 54%
Dense urban >3000 pop/sqkm 1,158 2.3 km2 / 0.9 km 13% 30%
KEY ASSUMPTIONS FOR 2020: 82.5 million unique subscribers 12,395 macro cell sites per operator 88% population / 55% geographical coverage
The cell sites are distributed according to user density with smaller cells in dense urban areas and larger cells in rural areas
SPECTRUM FOR MOBILE© GSMA 2014
NIGERIA: DEMANDS & RESULTSLower Scenario Middle Scenario Higher Scenario
Area type Data per user per month
Spectrum Requir.
Data per user per month
Spectrum Requir.
Data per user per month
Spectrum Requir.
Rural 0.7 GB 147 MHz 1 GB 179 MHz 1.4 GB 250 MHz
Sub urban 2.4 GB 464 MHz 3.6 GB 682 MHz 4.8 GB 899 MHz
Dense urban
4.9 GB 998 MHz 7.4 GB 1,482 MHz 9.8 GB 1,968 MHz
National Average
2 GB 998 MHz 3 GB 1,482 MHz 4 GB 1,968 MHz
The data traffic estimation per subscriber (not connection) differs according to area type and scenario
POTENTIAL FUTURE MOBILE BANDS
SPECTRUM FOR MOBILE© GSMA 2014
NEW BANDS FOR MOBILE
RADIO SPECTRUM: IDENTIFIED MOBILE BANDS
1.8G
Hz
2.1G
Hz
2.6G
Hz
450–
470M
Hz
Digi
tal D
ivide
nd
(700
/800
MHz
)90
0MHz
2.3G
Hz
3.4–
3.6
GHz
470–694/8MHz
3.4–3.8GHzCANDIDATE BANDS
FOR WRC-15
2.7–2.9 GHz1427–
1518MHz
3.8–4.2GHz
1300–
1400MHz
GSMA has agreed widespread mobile operator support for 4 new mobile allocations
– Sub-700MHz UHF (470-694/8MHz) – 2.7-2.9GHz– L-Band (1300-1518MHz) – C-Band (3.4-4.2 GHz)
These bands can be harmonised globally to drive lower cost equipment/services
– Pursuing other bands risks creating a fragmented market negatively impacting equipment choice, price, roaming ability and could create international interference issues
SPECTRUM FOR MOBILE© GSMA 2014
TARGET BANDSTARGET BAND
BENEFIT FOR MOBILE EXISTING USAGE HOW TO ACCOMMODATE MOBILE
Sub-700 MHz (470-694 MHz)
Extremely important for bringing high speed mobile broadband everywhere
Mostly broadcast
Broadcasters can use more spectrum-efficient tech
IPTV, satellite, cable & LTE broadcast to complement DTT
L-band (1300-1518 MHz)
Good general purpose band for coverage and capacity
(excluding 1400-1427 MHz)
Comms for aircraft control systems (ie. telemetry)
Military and civilian radar Fixed links (e.g. for business) Satellite phones Earth observation satellites
1452-1492MHz largely unused globally so ideal basis for a harmonised allocation
Radar & aeronautical mobile telemetry services could potentially use spectrum more efficiently
2.7-2.9GHz Excellent capacity band Could use existing 2.6GHz
base station sites easily
Air traffic control Military radar
Band is mostly under-used so could support mobile in a portion. Big exclusion zones not needed with small guard band.
C-band (3.4-4.2GHz)
Excellent capacity band Supports fastest services Suitable for urban/suburban
areas and small cells
Fixed Satellite Services (e.g. satellite TV and broadband)
Could segment the band at 3.8 GHz in some markets
Satellite providers can use smaller portion – they use other bands in tropics w/ new tech
Big exclusion zones not needed
SPECTRUM FOR MOBILE© GSMA 2014
SHARING UHF: THE ASSUMPTIONS ARE KEY
DTT Technology Required separation (km) between the edge of the IMT BS cluster and edge of the DTT coverage area
No mitigation With mitigation
ATSC 72 km 33 kmDVB-T (18 dB PR)
30 km 14 km
DVB-T (21 dB PR)
37 km 17 km
DVB-T2 (19 dB PR)
37 km 17 km
DVB-T (21 dB PR)
43 km 20 km
ISDB-T 72 km 33 km
Interfering field strength threshold @700 MHz
Initial separation distance R
Total cumulative field strength
Increase over original threshold
New required separation distance
[dB(mV/m)] [km] [dB(mV/m)] [dB] [km]23 61 43.4 20.4 212
Source: JTG 584 (DRAFT PDNRS)
BUT THESE CAN BE UNDERMINED WHEN ASSUMPTIONS ARENT REALISTIC (E.G. BY CHOOSING UNORTHODOX NETWORK TOPOLOGIES)
ALL THE GSMA’S PROPOSED BANDS REMAIN UNDER CONSIDERATION BY THE JTG AS THE TECHNICAL/SHARING STUDIES ARE POSITIVE
SPECTRUM FOR MOBILE© GSMA 2014
L-BAND: SHARING STUDIES
Service Co channel Adjacent channel
Radars
IMT downlink: One study indicates separation distance of 560 km under certain assumptions. Other studies indicate smaller distances, and mitigation can reduce distances further.IMT uplink: Co-ordination distances less that 5 km should be possible.
IMT downlink: Combination of frequency separation and mitigation (e.g. filtering, small exclusion zones) can enable compatibility between IMT downlink and radars.IMT uplink: Studies show < 2 km with 10 MHz guard band without mitigation, and lower if IMT emissions are below generic limits.
Fixed links
Co-ordination and mitigation can enable co-existence between IMT and fixed links in different areas
Separation distances at most a few kms with small guard band (e.g. 2 MHz)
EESS (earth exploration satellites)
Guard band of a few MHz to avoid interference to EESS. IMT emissions limits may need to be tightened.
A WORKING DOCUMENT HAS BEEN DEVELOPED AIMED AT INCLUDING THESE SHARING STUDIES IN THE PRELIMINARY DRAFT NEW REPORT (PDNR) FOR EACH SERVICE
SPECTRUM FOR MOBILE© GSMA 2014
2.7-2.9 GHz
A WORKING DOCUMENT TOWARDS INCLUDING THESE SHARING STUDIES IN THE RADAR PDNR HAS BEEN DEVELOPED
There are big differences between results of worst case studies under pessimistic assumptions and studies with more realistic assumptions and/or mitigation used One study indicates co-channel separation between IMT downlink and radar > 500km
under certain assumptions, while others calculate smaller distances A combination of frequency separation and mitigation (e.g. filtering, small exclusion
zones) can enable compatibility between IMT downlink and radars IMT uplink and radars can co-exist with frequency separation ~10MHz and physical
separation < 1-2km
SPECTRUM FOR MOBILE© GSMA 2014
C-band (3.4-4.2 GHz)THE SEPARATION DISTANCES BETWEEN IMT AND FSS ARE IN THE DRAFT NEW REPORT (DNR)
Co-channel case Adjacent Channel case
IMT Macro cell 27 km up to 525 kms 1.5 to 40 km
Required separation distances could be reduced by taking into account additional effects of natural and artificial shielding.
The separation distance can be reduced by employing a guard band
IMT small cell – outdoor
3 km up to exceeding 100km 60m to 5km
IMT small cell - Indoor
Less than 1 km to tens of km, and up to 120 km
50m to less than 5km
WHAT’S AT STAKE?
SPECTRUM FOR MOBILE© GSMA 2014
WHAT’S AT STAKE: MORE THAN JUST MHz
MOBILE DELIVERS MAJOR – AND GROWING – SOCIO-ECONOMIC BENEFITS WHICH WILL BE RESTRICTED WITHOUT ADDITIONAL SPECTRUM
SPECTRUM FOR MOBILE© GSMA 2014
WHAT’S AT STAKE: MORE THAN JUST MHz
20132020
SPECTRUM FOR MOBILE© GSMA 2014
Conclusion
THERE IS A SIGNIFICANT SPECTRUM SHORTFALL FOR IMT IN MANY MARKETS
UNLESS CONSENSUS EMERGES SPECTRUM MAY BE IDENTIFIED ON A NATIONAL BASIS LEADING TO INCREASED COSTS TO CONSUMERS OR LACK OF MOBILE DATA CAPACITY
GSMA believes that on average around 600-800 MHz probably needs to be identified Must be from harmonised bands comprising a mix of low and high frequency ranges GSMA believes that UHF, L band, 2.7/2.9, and some of C Band are the best candidates
based on:- How heavily the band is used and locations
E.G. This means part of C-Band can be used in urban areas for IMT – the rest for FSS in rural
2.7/2.9 MHz segmented to allow part of the band for IMT
11 APRIL 2013
© GSMA 2013
THANK YOU
SPECTRUM FOR MOBILE© GSMA 2014
MORE DATA = MORE SPECTRUM
On average 600-800MHz additional mobile spectrum needed by 2020 globally
Takes into account increasingly spectrum efficient technology (e.g. LTE-Advanced), network architectures (e.g. cell splitting & small cells) and Wi-Fi offload
This does not include existing ITU mobile bands that should be licensed to meet data demand today
More spectrum required to avoid a network slow down and higher consumer prices
New bands must be harmonised globally, or at least regionally, to create a wide range of low cost equipment and enable roaming
Coverage and capacity bands required for fast, low-cost, ubiquitous services Low frequency bands essential for
widespread mobile broadband access including rural area
SPECTRUM FOR MOBILE© GSMA 2014
WHAT IS GSMA DOING?
Create regional and national strategies to get support for our target bands
Participate in regional events - including CEPT, ASMG, RCC, ATU, CITEL and APT
Submit papers such as sharing studies into the WRC-15 process
Develop public facing position papers on the importance of future spectrum and our target bands
Outreach to key stakeholders: Government / Regulators – at
national, regional and ITU events Member operators – raising
awareness with C-level execs Ecosystem – support through in-
country engagement Thought leaders and influencers –
finding ‘ambassadors’ to champion our cause
SPECTRUM FOR MOBILE© GSMA 2014
Coleago Model
SPECTRUM FOR MOBILE© GSMA 2014
MAY JUNE JULY AUG SEPT OCT NOV DEC JAN FEB MARCH APRIL
CPM Report
Special committee
Publication of direct CPM text
2014 2015
Final JTG meeting
21-31 July 2014
National Regulator
RegionalGroups
APT, ATU, ASMG, CEPT,
CITEL,RCC
CPM - 15 Management
Team
CPM Meeting CPM - 15 - 2
Mobile Network Operators & Industry
WR
C -
15 G
enev
a
NOV
GETTING INVOLVED IN THE WRC-15 PROCESS
Key
Direct input
Indirect input
JTG process
CPM process
SPECTRUM FOR MOBILE© GSMA 2014
UPCOMING WRC-15 MEETINGS
MAY JUNE JULY AUG SEPT OCT NOV DEC
2014
MAY JUNE JULY AUG SEPT OCT NOVJAN FEB MARCH APRIL
2015
APGBrisbane
APG 4 China
APG 5 Korea
Dubai TBA Q3 - TBD
AfriSWoGKenya
ATU WRC PREP Nigeria
ATU WRC PREP TBD
PTD - 6 Lux
PTD - 7 CroatiaCPG - 15 - 5 France
PTD - 8 UKCPG - 15 - 6
PTD - 9 Lithuania
CPG - 15 - 7Turkey
CPG - 15 - 8
PCC11Mexico
PCC11TBA
PCC11USA
TBA TBA TBA TBA TBA
WRC
- 15 G
enev
a
SPECTRUM FOR MOBILE© GSMA 2014
MAJOR UPCOMING ITU MILESTONES
The last Joint Task Group (JTG) meeting in July will finalise the draft Conference Preparatory Meeting (CPM) text
The CPM text is very important – Provides the technical evidence
for consideration at WRC-15 including sharing feasibility and options for developing regulations for the target bands
– Member states around the world, in particular developing countries who do not participate in the JTG & CPM meetings, use the CPM Report to develop their positions/proposals for WRC-15
Member engagement through their respective NRA is essential to ensure that:– The GSMA’s target bands are
included in the CPM Text– Analysis of sharing studies
reflects results of all studies submitted to the JTG
– CPM text dealing with methods to make new spectrum available for mobile broadband is balanced and reflects all possible technical and regulatory approaches to deal with incumbent services