Please find below the Federation of Communication Services (FCS) response to your consultation “Enabling short notice, short duration licences in 2.3 GHz”.  We have not provided answers to your individual questions, but we do have a couple of important points of principle to share.  I can confirm that our response is not confidential, and we are happy for it to be shown on the Ofcom website.

The FCS represents companies which provide professional communications solutions to business users. Our members deliver telecommunications services via mobile and fixed line telephony networks, broadband, satellite, wi-fi and business radio. Our members’ customers range from SMEs, home-workers and micro-businesses up to the very largest private enterprises and public sector users. FCS is the largest trade organisation in the professional communications arena, representing the interests of circa 350 businesses which supply B2B services nationwide.

The FCS welcomes the opening of spectrum and increased sharing believing that it provides new opportunities to add value and to contribute to growth. Accordingly, the FCS welcomes this consultation and proposals that promote the efficient use of spectrum and facilitates the opportunity to promote a greater variety of services.  It is, however, important that Ofcom addresses the potential of interference and the FCS believes that a key element of the proposals should be to ensure that the new approach does not create instances of Harmful Interference.  Ofcom performs assessments for SS-DAB deployments, and these have generally worked well and should be used as a model for short duration services.

Please let me know if you would like to discuss our response in more detail and it would be very helpful if you could confirm receipt of our response.

Many thanks,

Stefanie

Stefanie Norman
Head of Regulation and Public Affairs
For the Federation of Communication Services