QUALCOMM International Inc.

Telecommunications Regulatory Authority Consultation TRA Spectrum Band Plan 694-862 MHz Qualcomm Response July 2012

Introduction

Qualcomm highly appreciates the opportunity to provide comments on TRAs plans for the future use of the 694-862 MHz band.

Mobile broadband is a strategic national infrastructure which has been recognized as a key element to obtain a national competitive edge and is crucial for a sustainable economic growth. The digital platform is enabling key efficiency gains for high priority societal services through innovation, e.g. in the fields of e-health, egovernment and e-safety. The nationwide availability of quality mobile broadband access is opening up a vast array of opportunities that is already making an impact on citizens lives, and is sure to make a bigger impact in the future.

Furthermore, users are more and more turning to mobile internet. Mobile computing has recently experienced exponential growth in scale and breadth of penetration. The popularity of devices such as smartphones, dongles and tablets as well as other connected devices such as video games, embedded appliances and sensors has extraordinarily increased as they have become more affordable. Demand for ubiquitous internet access in wireless mode and with a predictable Quality of Service

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is increasing as consumers turn to mobile access to complement or substitute fixed broadband access.

As such, it is clear that the mobile broadband infrastructure will be the basis not only of a countrys future economic competitiveness, but more generally of the users and citizens digital lives.

Qualcomm applauds TRA for identifying the frequency bands below 1 GHz as the critical tools to enable the roll-out of a countrywide mobile broadband infrastructure. The 900, 800 and 700 MHz bands will provide the backbone of the future mobile broadband networks, since they will enable the universal availability of mobile broadband, i.e. will define the Quality of Service level that can be expected in a given country.

Qualcomm shares TRAs opinion that the most favourable 800 MHz band for UAE is the 3GPP band 20, described in TRAs consultation as the Option 1 (FDD arrangement). This band plan is already widely supported with more than 72 devices available as of April 2012.1 The band has already been awarded in major countries like Germany, France, Spain and Italy. Networks deployment started and commercial services are in place. The band will be awarded in the 27 countries of the European Union by end of 2013 at the latest2, creating considerable more scale. Furthermore, Arab countries are expected to implement this band plan which can bring further economies of scale and roaming opportunities to UAEs customers and citizen in region.

Qualcomm fully supports TRAs proposal to consider on the longer term the implementation of a 703-733/758-788 MHz band plan in the 700 MHz band. This band plan will leverage the 700 MHz APT band plan (3GPP Band 28), is fully

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Source: GSA EU Radio Spectrum Policy Programme 2

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compatible with the proposed 800 MHz band plan (3GPP Band 20) and will make 2x95 MHz of harmonised frequencies available for mobile broadband below 1 GHz (2x35 MHz in 900 MHz, 2x30 MHz in 800 MHz and 2x30 MHz in 700 MHz). Furthermore, Qualcomm is promoting this 703-733/758-788 MHz band plan in Europe for the 700 MHz in order to enable its adoption on a very wide basis, ensure roaming and seamless mobile broadband services.

Qualcomm congratulates TRA for its visionary proposals and fully supports its proposed approach to mobile broadband in the sub-1GHz bands.

Question 1: Do you have any comment on the above?

Qualcomm applauds TRAs commitment to support the UAEs ICT sector. Qualcomm believes that TRAs initiatives and leadership will enable the UAE to develop world class ICT infrastructures that will benefit not only the ICT sector, but UAE in general. Beside the facts summarised by TRA, Qualcomm wishes to underline that the Geneva-06 Regional Agreement is flexible enough to allow for uses of the 694-862 MHz range other than broadcasting. For example, a number of European countries, which are also signatories of the Geneva-06 Regional Agreement, have deployed mobile broadband infrastructure in the band 790-862 MHz. The flexibility offered by the Geneva-06 Regional Agreement enables UAE not only to match European deployment in the 790-862 MHz, but also to become a world leader in ICT infrastructures by deploying mobile broadband in the 694-790 MHz band. Therefore, the Geneva-06 Regional Agreement should not be seen as a restriction, but on the contrary as an opportunity for UAE, as it offers sufficient flexibility for UAE to deploy world class ICT infrastructures in the short term.

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Question 2: Do you have any comment on the TRA issuing the band plan but allocating spectrum only when the band is vacated by the analog broadcasting?

Qualcomm fully supports TRAs proposed way forward. Qualcomm further applauds TRAs commitment to actively seek the full availability of the 800 MHz band by December 2012. Mobile Network Operators need long term certainty to plan investment, which requires an accurate and forward looking vision on the future band plans available for Mobile Broadband. Qualcomm believes that such vision is accurately provided by TRA, including through the present consultation. At the same time, infrastructures can only be deployed once the band is vacated by the analogue broadcasting. Mobile Network Operators may plan potential deployment a few months in advance, but any substantial network deployment would probably require the band availability. Qualcomm recommends TRA to work in close relationship with MNOs in order to determine the optimal point in time to conduct the spectrum allocation.

Question 3: Which arrangement option do you prefer and why?

Qualcomm supports the option 1, i.e. the FDD arrangement, for a number of reasons, both technical and economical.

Technical grounds The significant benefits of the 800 MHz bands are due to the favourable propagation characteristics offered by the band. That is, the most benefits are derived from the 800 MHz band when it is used as a coverage frequency band, especially for deep indoor or large areas. Time Division Duplex (TDD) is a duplex scheme that is favourable for high capacity areas, short coverage areas. However, for large coverage, TDD may suffer from very large round trip time which would require large DownLink (DL)/UpLink (UL) switch time (wasted time slots). For coverage cells, Frequency
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Division Duplex (FDD) is most recommended and will offer superior Quality of Service (QoS) at reduced cost. Furthermore, synchronisation of mobile networks from competing operators is usually cumbersome. When synchronisation is not achieved, a guard band between concurrent TDD networks is required. Such guard bands would limit the efficiency of the TDD band plan. Finally, The FDD band plan clearly identifies the UL and DL frequency domain which facilitates coexistence measures with services in adjacent frequency bands.

Economical grounds The Option 1 (FDD arrangement) corresponds to the CEPT preferred arrangement and has already been allocated in France, Germany, Italy, Portugal, Spain and Sweden, with other European Union countries to allocate the spectrum following this frequency arrangement before the end of 2013 3 . The FDD arrangement benefits therefore from a very large ecosystem which triggers the wide availability of equipment and drives the cost down. Germany provides a clear example of the benefits that a country can derive from such a large ecosystem. Germany issued licences following the FDD arrangement in May 2010. Germanys primary goal while issuing licences was to reduce the digital divide, i.e. to ensure that citizen with no broadband internet access would be provided mobile broadband services. 2 years after the issue of the licences, 10 out of the 13 regions presenting internet white zones are covered by networks in the 800 MHz band.4 That is, Germany managed to eradicate most of the digital divide in its territory in less than 2 years due to the leverage from the very large 800 MHz ecosystem.

Radio Spectrum Policy Programme

http://www.bundesnetzagentur.de/cln_1912/DE/Sachgebiete/Telekommunikation/Reg ulierungTelekommunikation/Frequenzordnung/OeffentlicherMobilfunk/VergabeVerfa hrenDrahtlosNetzzugang/Versorgungsverpflichtung800MHzFreqs_Basepage.html

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As of April 2012 (i.e. less than 2 years following the first 800 MHz roll out), 72 devices already support the 800MHz band.5 Smartphones supporting LTE 800 have been available since early 20126 and further models from the most main OEMs are expected for release in 2012.

Last but not least, Qualcomm expects a number of countries from the GCC countries and more generally from the Middle East and North Africa region, to adopt the Option 1 (FDD arrangement) very soon. Qualcomm recommends TRA and other regulators from the MENA region to adopt the option 1 (FDD arrangement) in order to ensure a) economies of scale with other countries from the region for operators, b) simplified cross-border coordination for administrations and c) transparent roaming for end users.

Question 5: Do you have any comments on the vacation of 694-790 MHz by analog broad-casting?

Qualcomm applauds TRAs leadership to allocate the band for mobile broadband services by WRC-15 or even earlier. Qualcomm believes that the 700 MHz band offers a unique opportunity for TRA and the UAE to offer a combined 2x60 MHz for mobile broadband services in the 800 and 700 MHz band, besides the already available 2x35 MHz in the 900 MHz band. The availability of 2x95 MHz of sub1GHz spectrum for mobile broadband would ensure the UAE a world leading, cutting edge mobile broadband infrastructure in 2015, which would not only eradicate the digital divide but also virtually ensure the availability of a world class ICT infrastructure in the UAE. Given the large impact of ICT on the economic performance of companies and countries, such infrastructure would guarantee a substantial competitive edge for UAEs companies.

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Source: GSA E.g. Htc Velocity 4g, HTC One XL, Samsung Galaxy S2 LTE. 6

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Question 6: Do you have any comments on the above principles?

Qualcomm fully supports the objectives set out by TRA to develop the band plan. Qualcomm notes that mobile broadband infrastructure have demonstrated in the past that they do provide for efficient and best use of spectrum, that the adoption of the band
plans ensuring 2x95 MHz of sub-1GHz mobile broadband spectrum will bring outmost

benefits and that the band plans supported by TRA provide favourable conditions for
economies of scale and roaming opportunities in the 700 (3GPP Band 28 lower duplexer), 800 MHz (3GPP Band 20) and 900 MHz (3GPP Band 8) bands.

Question 7: Do you have any comments on the above band plan?

Qualcomm fully supports the band plan proposed by TRA. Qualcomm underlines that such a band plan ensures the availability of a combined 2x95 MHz of sub-1GHz spectrum for mobile broadband. Furthermore, such a 700 MHz band plan is fully compatible with the 800 MHz band plan (Option 1, FDD arrangement) which will very soon be adopted and support mobile broadband services throughout the GCC and Arab countries in general. At the same time, Qualcomm is promoting the adoption of this 700 MHz band plan proposed by TRA in Europe also in order to enable harmonisation and create scale. Finally, Qualcomm notes that the proposed 700 MHz band plan corresponds to the lower duplexer of the Asia Pacific Telecommunity (APT) 700 MHz band plan, namely Band 28 of 3GPP. Therefore, the sub-band 703-733/758-788 MHz band is expected to be available in many countries globally. Finally, Qualcomm notes that further studies are required in order to identify the best use of the 733-758 MHz band. Qualcomm supports a harmonised use of this frequency band.