Mobile Services on Aircraft Response


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Vodafone UK response to Ofcom discussion paper on the introduction of mobile services on aircraft
Summary
Vodafone supports the development of innovative, new approaches to offering data and voice communications services to passengers on civilian aircraft.
If data and voice communications use is to be encouraged more widely on board civilian aircraft, this will have the greatest chance of success where customers are permitted to use their existing mobile devices. For this reason Vodafone supports the use of GSM 1800 frequencies within aircraft to meet in-flight communications needs.
Ofcom’s consultation on this subject is timely and is a valuable exercise in transparent decision making by national regulatory agencies in Europe and internationally.
Air safety considerations
In-flight GSM frequency use must first be supported by European civil aviation regulators and airlines, who must be convinced that air-safety considerations will not be compromised by what is proposed. Vodafone does not believe that there should be any change to the status quo regarding mobile use on aircraft unless this is given unambiguous regulatory approval by aeronautical safety authorities.
Ensuring continued air-safety must be a primary concern. This must include effective measures for the management of both technical and human air-safety factors.
Management of interference with existing, terrestrial GSM networks
From the perspective of an existing GSM operator, interference limits must ensure that the operation of terrestrial GSM networks is not compromised by proposed in-flight use of GSM frequency bands.
The operation of GSM devices in planes must include effective management of interference to internationally accepted limits as proposed in recent CEPT work on this subject. How these limits will be met in practice must be for the specific system providers to demonstrate.
The use of GSM mobiles on board participating aircraft should only be permitted once a designated minimum height is reached and should be prohibited from take-off to that height and from that height to landing. Proposed prohibitions on use below an agreed height must be rigorously enforced by airline staff. In practice, this will ultimately be under the control of the captain of the relevant aircraft who must have responsibility for ensuring this.

Vodafone UK

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Introduction of mobile services on aircraft

23/06/06

Vodafone notes that the draft CEPT Decision ECC/DEC(06)FF defines a minimum height for operation of the onboard system of 3000m above ground. This height is a consequence of the scope of the studies rather than a fundamental limit. Vodafone believes that regulators should not rule out a reduction of this limit in future based on analysis of the degree of interference encountered in practice and on the practicality of having different heights and periods of any flight at which the use of different devices is permitted on participating airlines.
Any attempted GSM use by passengers on non-participating airlines should continue to be prohibited and these prohibitions must be rigorously enforced by airline staff. This will require agreement on the systematic management of this issue across the airline industry serving countries which choose to authorise in-flight use of GSM. This must include both participating and non-participating airlines.
Basis of regulation
National responsibility for spectrum allocations can be taken to extend “upwards” to include aircraft flying above a national geographical territory. However, in practice Vodafone recognizes this does not provide a good basis of regulation of international inflight services.
For reasons of practicality and efficiency Vodafone believes regulation of GSM frequencies on board aircraft should be managed by the home national radio administration of the airline concerned. This would amount to a “flag-carrier” arrangement.
Mutual recognition of satisfactory minimum approaches among sovereign national radio administrations will be required for this to operate effectively. Vodafone would support a collaborative approach between European administrations to develop a common regulatory and technical approach which will address stakeholders’ concerns. We believe that agreement on a common approach will both facilitate service roll out and will avoid the risk of an unsatisfactory discriminatory situation between market participants based in different CEPT countries.
Practical issues regarding the resolution of international interference (GSM operator in country A, interfered with by a plane operated on a flag country basis by an in-flight operator serving an airline located in country B) must have a way of being be resolved satisfactorily on an international basis.

Vodafone UK

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Introduction of mobile services on aircraft

23/06/06

Licensing of in-flight GSM systems
Ofcom raises the question as to whether GSM systems on board aircraft should be licence exempt, in accordance with the provisions of the EU Telecoms framework.
Vodafone is strongly against any licensing approach based on licence exemption of the in-flight systems.
Under the Authorisation Directive, EU Member States must, when the risk of harmful interference is negligible, make the use of radio frequencies licence exempt1. For harmful interference to be avoided, four conditions must be met: - The power of the onboard base station must be low enough not to cause
interference to GSM networks on the ground (but be high enough to provide the onboard GSM service). - The power of any active network control unit (if used) must be high enough to mask mobile networks on the ground from terminals onboard the aircraft. - The power of the network control unit must be low enough to avoid causing interference to networks on the ground in any of the bands in which it operates. - The onboard network must not be operated below the specified minimum height.
The level of interference which will be caused by in-flight systems is dependent on the antenna system used onboard the aircraft and the shielding provided by the cabin fuselage. It will therefore be necessary to determine the correct base station and network control unit transmission power for each distinct configuration of equipment and aircraft. There is a substantial risk of interference occurring if this is not done correctly.
If GSM onboard systems were licence-exempt, national administration would not have any record of which aircraft have systems installed. It would then be impossible to identify which aircraft was at fault if interference occurred, or to ensure that the operational procedures to avoid interference were being followed.
While Vodafone would wish to encourage the development of on aircraft systems it is inappropriate for these systems to be licence exempt given their high potential to cause interference with terrestrial networks. The risk of harmful interference to other users from in-flight systems certainly cannot be described as “negligible”
Ofcom has proposed 3 alternatives in terms of the licensing regime. These are that systems would be licensed to:
(i) the captain of the aircraft;
(ii) the aircraft owner or operator; or
(iii) a third party operator or installer of the aircraft.
For GSM onboard aircraft to be introduced in an orderly way, the authorisation and licensing approach must be consistent between European countries or, at least, the approaches of participating countries must be acceptable to each other. This issue must be agreed internationally.

1 Directive 2002/20/EC of the European Parliament and of the Council of 7 March 2002, on the authorisation of electronic communications networks and services; Article 5.1.

Vodafone UK

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Introduction of mobile services on aircraft

23/06/06

Each of Ofcom’s proposals has some merit and can be made to work effectively assuming that there is common European agreement on the approach or approaches which are acceptable.
The captain of the aircraft
Vodafone anticipates that responsibility for switching off systems below 3000m must be included as a formal condition in the wireless license for onboard GSM systems to provide the required reassurance to terrestrial network operators. If, in practice, this will be the responsibility of the Captain, then this must either be taken into account in licensing or otherwise provided for through contract.
However, licensing an individual to operate an in-flight system would potentially place a range of other relatively complex requirements on an individual whose area of specialist knowledge is elsewhere. It would also proliferate the administration of in-flight communications as the number of licences would be required to reflect all potential pilots.
The aircraft owner or operator
For these reasons it may be more appropriate for the licensed entity to be the aircraft owner (or operator). In particular, this would follow the logic of flag country regulation. A single licence should be offered to cover all of the aircraft of one owner and would only be needed in the country of registration of the aircraft.
The aircraft owner will have contractual relationships with both the third party operator and with the captain and so can ensure that licence requirements are reflected in contract where required.
The third party operator or installer of the aircraft
This is another viable alternative. The in-flight system operator would logically have the expertise to secure necessary licenses for the use of the system which it provides. This would be similar to the way other communications networks including terrestrial mobile networks and satellite networks currently operate. In this case the in-flight system operator would again seek a single licence for the operation of services from aircraft registered in an individual country.
Vodafone would support either of the aircraft or system operator as the licensed entity.

Vodafone UK

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Introduction of mobile services on aircraft

23/06/06

Vodafone’s responses to Ofcom’s specific questions
Q1: Should the provision of services using GSM at 1800MHz be allowed on aircraft if the terrestrial networks and avionic systems are not compromised? Given Ofcom’s statutory role, what other factors, if any, should inform a decision to allow the use of these services on aircraft?
Vodafone supports the development of innovative, new approaches to offering data and voice communications services to passengers on civilian aircraft.
If data and voice communications use is to be encouraged more widely on board civilian aircraft, this will have the greatest chance of success where customers are permitted to use their existing mobile devices. For this reason Vodafone supports the use of GSM 1800 frequencies within aircraft to meet in-flight communications needs.
From market investigations there appears to be significant market demand for in-flight communications. On the other hand a proportion of passengers are not enthusiastic regarding the use of voice services by others during flights. Vodafone believes that airlines and their in-flight operator partners will have to engage in substantial market testing before deciding on the approach which works best for their customers.
Q2: Is a multilateral rather than a unilateral approach to enabling these types of service appropriate?
For GSM onboard aircraft to be introduced in an orderly way, the authorisation and licensing approach must be consistent between countries, or at least the approaches of countries must be acceptable to each other. This issue must be agreed internationally.
Q3: Should the equipment for mobile services on aircraft be licence exempt?
No, while Vodafone would wish to encourage the development of on aircraft systems it is inappropriate for these systems to be licence exempt given their high potential to cause interference with terrestrial networks. It cannot be the case that the risk of harmful interference to other users from in-flight systems can be described as “negligible”.
Q4: If licensing for use of the equipment on board aircraft is required, who should hold the licence?
Vodafone would support either the aircraft or system operator acting as the licensed entity. Each of these options has practical advantages.
Q5: What considerations (practical or otherwise) are relevant to compliance by the operators of on-board GSM systems with the General Conditions of Entitlement?
In terms of how the UK General Conditions of Entitlement should be applied to in-flight systems Ofcom’s recent approach to their application to Voice over IP suppliers provides a model. Regulation should ensure that the objectives of the General Conditions are adhered to in the case of in-flight GSM use without being rigid over precise technical implementations.

Vodafone UK

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Introduction of mobile services on aircraft

23/06/06

Q6: Do you have any comments in relation to competition in the provision of these services?
Vodafone understands that the proposed GSM onboard systems will support roaming on in-flight networks by existing GSM operators. Backhaul from the aircraft will be via satellite. Vodafone believes that this will provide an appropriate business basis for inflight use.
Assuming a roaming-type approach Vodafone would raise the question of the viability of proposed GSM in aircraft business models if proposed controls of European roaming pricing were to be introduced. In particular, it seems unlikely that calls to a national mobile number of a customer on an aircraft could be made on commercially viable terms unless it is possible to charge the customer receiving the call for its in-flight termination.
This provides an illustration of the effect of price controls on new, innovative services. Scope for ex post application of competition law should be sufficient to provide for necessary consumer and industry protection.
Q7: Should international mobile network codes be allocated to these on-board mobile systems rather or national codes?
Vodafone supports the use of international mobile network codes for on-board systems.
Q8: Has this discussion paper highlighted the key issues, discussion points and posed the right questions?
Ofcom’s consultation on this subject is timely and is a valuable exercise in transparent decision making by national regulatory agencies in Europe and internationally.
Vodafone notes that there is a proposed CEPT Decision with regard to the minimum altitude where in flight operation of mobile phones will be permitted. This proposed a 3000m lower limit as a consequence of what was studied rather than a fundamental limit. Vodafone believes that regulators should not rule out the reduction of this limit in future based on analysis of the degree of interference encountered in practice and on the practicality of having different heights and periods of any flight at which the use of different devices is permitted on participating airlines.

Vodafone UK

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Introduction of mobile services on aircraft

23/06/06

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Mobile Services on Aircraft Response